This is the third course in Tax Academy's Transfer Pricing Certification. This certification will provide you with the relevant skills to apply transfer pricing knowledge in less than two months. In this course, you will learn about some of the most important concepts of transfer pricing or TP, such as the assessment procedure, the Advance Pricing Agreement or APA scheme and issues related to the intra-group services.
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You will build knowledge about the academic and practical aspects of the transfer pricing litigation, appeal and assessment proceedings in India. You will also understand the importance and the procedural mechanism of an APA. You will further understand the concept of intra-group services or IGS and why the same is one of the most litigative issues in the Indian transfer pricing framework, along with learning how to prepare a robust documentation in support of the arm’s length nature of the intra-group services.
Learners who complete this certification can gain the skills required to apply to introductory job positions in the industry or consultancies.
What you'll learn
- Understand the academic and practical aspects of the Indian transfer pricing assessments and appeal.
- Learn about the penalty provisions as prescribed under the Indian transfer pricing laws.
- Describe the concept of APA and its importance along with the legal provisions governing the practical and procedural aspects.
Syllabus
TP assessments, time limits and penalties
Module 1
In this module, we shall outlay the concept and laws in relation to the transfer pricing assessments and appeals along with the time limits and penalty provisions as prescribed in the Indian Transfer Pricing laws. The module will help you understand the legal provisions relating to the assessments procedure, the role and powers of the Assessing Officer and Transfer Pricing Officer and the prescribed time limits for furnishing the requisite information and completion of the procedure. You will also gain an understanding of the applicable penalties in case of non-compliance.
Overview of APA
Module 2
APA is an advance pricing agreement between the Indian taxpayers and the tax authorities for determination of the arm’s length price or manner of computation of ALP for a continuing or future international transaction. In this module, we shall explain the concept of APA, commonly known as APA, and the key considerations and the benefits of entering into an APA. We shall also discuss the various types of APA, the administrative compliances and the procedural aspects.
Intra Group Services
Module 3
In this module, we shall explain the concept of intra-group services. Intra-group services are one of the most litigative issues in the Indian as well as global litigation landscape. Therefore, it will be interesting to discuss various nuances involved in the evaluation of the arm’s length price for intra-group services. In this module, we shall cover the perspective of taxpayers and tax authorities for intra-group services. We shall also discuss the various categories of intra-group services and the guidance prescribed in the Organisation for Economic Co-operation and Development TP Guidelines and United Nations TP Manual. The module will also provide an overview of certain landmark judgements as reading materials, which will help you gain a deeper understanding of the approach by the appellate authorities.
