International Business and Transfer Pricing: Concepts and Jurisprudence by S. C. Mishra offers an in-depth and analytical exposition of the principles governing international taxation and transfer pricing, blending legal interpretation, business strategy, and economic reasoning. This 2025 Edition comprehensively examines the global and Indian frameworks governing transfer pricing, focusing on BEPS (Base Erosion and Profit Shifting), OECD Guidelines, and the Indian Income-tax Act, while aligning the theoretical foundations with real-world practices.
The book serves as an essential guide for tax practitioners, multinational enterprises, academicians, and policy professionals seeking to understand the complexities of transfer pricing in an evolving international business environment.
🔍 Key Features:
🌍 Comprehensive Framework:
Covers the conceptual, legal, and economic dimensions of international business taxation and transfer pricing, offering a holistic understanding of global compliance frameworks.⚖️ Jurisprudential Depth:
Provides detailed commentary on Indian and international judicial precedents, including major rulings on arm’s length pricing, intangibles, cost-sharing arrangements, and intra-group services.💼 Practical Insights:
Offers actionable guidance on comparability analysis, functional analysis (FAR), selection of the most appropriate method, and documentation practices in line with regulatory expectations.📊 Updated Regulatory Developments:
Incorporates the latest OECD Transfer Pricing Guidelines (2022), BEPS 2.0 (Pillar One and Two) developments, and Indian CBDT circulars and notifications applicable up to 2025.📚 Doctrinal and Economic Integration:
Explains how economic theory, accounting standards, and tax jurisprudence intersect in designing effective transfer pricing policies.🧾 Compliance Simplified:
Includes templates, compliance checklists, and procedural overviews for Form 3CEB, Master File, CbCR, APAs, and Safe Harbour Rules.💡 Case Law Analysis:
Discusses landmark Indian and global decisions such as Maruti Suzuki India Ltd., LG Electronics, Sony India, and Cushman & Wakefield to illustrate practical applications of transfer pricing law.🧮 Emerging Topics:
Explores the impact of digitalization, cryptocurrency transactions, fintech valuation, ESG reporting, and cross-border data transfer pricing challenges.
📚 Coverage at a Glance:
Part I – Foundations of International Business & Taxation
Evolution of cross-border taxation and transfer pricing
Key concepts: value creation, profit allocation, and economic substance
Global convergence through OECD and UN models
Part II – Legal and Institutional Framework
Detailed study of Sections 92 to 94 of the Income-tax Act, 1961
Transfer Pricing Rules, 2001 – legal procedures and interpretation
OECD and UN Model Convention comparison
Safe Harbour and Advance Pricing Agreements (APA) mechanisms
Part III – Economic and Functional Analysis
FAR (Functions, Assets, and Risks) analysis
Determination of arm’s length price (ALP)
Application of methods – CUP, RPM, CPM, TNMM, and PSM
Challenges in benchmarking and selecting comparables
Part IV – Documentation, Litigation & Dispute Resolution
Transfer pricing audit process and penalty framework
Mutual Agreement Procedures (MAP) and Dispute Resolution Panel (DRP)
Practical strategies for defending transfer pricing assessments
Part V – Global Trends & Future Developments
BEPS Action Plans and global tax reforms
Impact of Pillar One (Digital Taxation) and Pillar Two (Global Minimum Tax)
Evolving standards of fairness and transparency in global taxation
🎯 Recommended For:
Chartered Accountants, Tax Consultants, and Legal Practitioners engaged in international taxation and transfer pricing cases.
Corporate CFOs, Finance Heads, and Tax Managers of multinational enterprises.
Students of CA, CS, CMA, LLB, LLM, and MBA (Finance) preparing for exams or research in taxation and international business.
Policy Analysts and Academicians exploring the interface between global taxation and economic regulation.
⭐ Why This Book is Essential:
This latest edition by S. C. Mishra provides a well-balanced fusion of theory, practice, and jurisprudence, offering clarity in an area marked by complexity and continuous evolution. With its comprehensive treatment of both legal and economic principles, the book stands as an indispensable reference for professionals, regulators, and researchers dealing with transfer pricing and international business law.
📚 International Business and Transfer Pricing: Concepts and Jurisprudence (2025 Edition)
By S. C. Mishra, Published by Commercial Law Publishers, remains a definitive and forward-looking guide to mastering global tax dynamics and compliance strategy in the modern economic landscape.
