The United Nations has recently released a publication namely Practical Manual on Transfer Pricing. The Manual is said to contain valuable discussions on a large number of important topics related to the subject of Transfer pricing. There is a detailed discussion on the different types of transfer methods available for calculation of transfer price, such as CUP, TNMM etc. It also explains the respective merits and demerits of each method. Some practical examples and case studies have also been provided which aim at explaining the circumstances in which a particular method would be suitable to use.
A detailed discussion on how comparables should be selected and how a comparability analysis needs to be conducted, has also been added. In addition to the above, a detailed discussion on the transfer pricing implications of marketing intangibles such as trade marks, technical know-how etc are also there. These become very relevant in the light of a case L.G.Electronics vs. ACIT 140 ITD 41 (SB). There is also a write-up on the laws & practices being followed in India and other countries.
The Manual will prove invaluable for all professionals seeking in-depth understanding of transfer pricing concepts.
