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Book Law of Income Tax  Sections 90 to 138

Download or read book Law of Income Tax Sections 90 to 138 written by Alayavalli C. Sampath Iyengar and published by . This book was released on 2017 with total page 6916 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Book The Law of Income Tax

Download or read book The Law of Income Tax written by Alayavalli C. Sampath Iyengar and published by . This book was released on 2005 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Book FEMA Ready Reckoner with Commentary  2 Volumes   Sixth Edition

Download or read book FEMA Ready Reckoner with Commentary 2 Volumes Sixth Edition written by R.Sridhar, and published by Bloomsbury Publishing. This book was released on 2021-09-15 with total page 2695 pages. Available in PDF, EPUB and Kindle. Book excerpt: About the Book The book seeks to provide readers with a practical insight into provisions of FEMA and associated laws in the form of commentary. General focus of exchange control laws has gradually shifted over time to compliance, reporting and documentation. Given that FEMA provides for significant penalty and prosecution; there is little room for non-compliance. This book is an attempt to provide professionals and compliance officers with essential knowledge and tools to understand and undertake the necessary compliances. The book provides the latest position without compromising on changes in the law that have taken place over time. This book aims to equip professionals, be it CS, CA, CMA or corporate lawyers, who are desirous of undertaking compliances or practicing on exchange control laws with the requisite knowledge and expertise. It seeks to be a practical guide to interpretation and compliances under exchange control laws. The book promises to be the go-to resource for exchange control laws for current and would be professionals and compliance officers.

Book Subhash Chandra Garg   s Explanation and Commentary on Budget 2024 2025   Outcome of Budget 2022 2023   Implementation of Budget 2023 2024

Download or read book Subhash Chandra Garg s Explanation and Commentary on Budget 2024 2025 Outcome of Budget 2022 2023 Implementation of Budget 2023 2024 written by Subhash Chandra Garg and published by Leadstart Publishing Pvt Ltd. This book was released on with total page 586 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Government of India spends about 15% of India’s GDP, which translated into a whopping expenditure budget of Rs. 48.2 trillion for 2024-25, including Rs. 11.11 trillion on capital expenditures, another 11.6 trillion on interest payments, more than Rs. 4.2 trillion on subsidies like food and fertilisers, over Rs. 5 trillion on centrally sponsored programmes in the states and many other expenditures. The budget expenditures impact everyone, individuals, households, workers, businesses and everything we care about–growth, inflation, welfare and governance of the country. This book explains everything relating to the expenditures programmes of the government. The government’s tax proposals generate all-round interest. Companies worry about tax on their goods, profits, equities and bonds. Households and individuals look at the budget speech proposals how their salaries, savings and capital gains are going to be affected. The wider investment community wants to figure out the government's disinvestment, privatisation, dividends and other non-tax receipts. All the tax, non-tax, disinvestment and privatisation proposals and performance of the government have been thoroughly analysed and commented upon in the book. The economists, media, banks, foreign portfolio investors, investment managers, brokerages and everyone else with a direct or indirect stake in India’s economy, savings, credit, financial markets and any other macroeconomic aspect watch very carefully, in addition to expenditure and tax proposals, the proposals of the budgets impacting macroeconomy. This book presents an in-depth analysis of the macro-economic performance of the Indian economy and the implications of budget proposals. The book is organised in four parts and 40 chapters. The first part has all the big budget numbers with highlights, the second part brings out the results and outcomes of Budget 2022-23, the third part takes a serious look at the implementation of Budget 2023-24 and the fourth part critically analyses the implications of the proposals in Budget 2024-25 presented on 23 July. All the three budgets have also been rated on a sound framework taking into account 2022-23 actuals, 2023-24 revised estimates and 2024-25 budget estimates.

Book Critical Commentary on the Banning of Unregulated Deposit Schemes Act  2019 and Allied Laws

Download or read book Critical Commentary on the Banning of Unregulated Deposit Schemes Act 2019 and Allied Laws written by Suraj Surjit Chaudhary and published by Bloomsbury Publishing. This book was released on 2021-03-15 with total page 498 pages. Available in PDF, EPUB and Kindle. Book excerpt: About the book With the passage of time, the existing State Depositor Protection Laws have proven inadequate in protecting the general public from unscrupulous deposit-taking firms. Parliament has though it fit to remedy the situation by bringing out Banning of Unregulated Deposit Schemes Act, 2019. While there is no end to the kingdom of knowledge in this fast-changing society, there was dearth of suitable books on Depositor Protection Laws. This book is a brief, analytical, section-wise legal commentary on the recently enacted Banning Act which is an umbrella law covering all kinds of deposits-Central and State. It attempts to highlight and analyse the various issues, problems, short-comings, lapses and merits in the Banning Act and allied laws in the backdrop of the litigation surrounding the various State/UT Acts that this new Central Act replaces. This book will be of value to anyone concerned to understand the rights and remedies under this law. It would be immensely useful for legal practitioners, company secretaries, chartered accountants, law makers, enforcement agencies, judges and depositors. Key features This book is an exhaustive treatise on the Banning of Unregulated Deposit Schemes Act, 2019 including - Detailed analysis of judicial precedents relating to the constitutional vires of Central Deposit Law and State Deposit Laws; Compiles and analyses various judicial precedents relating to pari materia provisions found in State Deposit Laws; Detailed analysis of amendments carried out in other laws, including the Securities and Exchange Board of India Act 1992, and the Reserve Bank of India Act 1934; Detailed analysis of related laws, including the Delhi Special Police Establishment Act 1946; Detailed analysis of priority of depositors qua the provisions of the Insolvency and Bankruptcy Code, 2016; Covers latest developments in law including those relating to crypto-currency; Covers the public consultation papers issued by the Central Government; and Detailed coverage of related foreign deposit related laws, including the law of United Kingdom from where important aspects have been borrowed and incorporated in the Act.

Book FEMA Ready Reckoner with Commentary  2 Volumes

Download or read book FEMA Ready Reckoner with Commentary 2 Volumes written by R.Sridhar, and published by Bloomsbury Publishing. This book was released on 2021-05-30 with total page 3158 pages. Available in PDF, EPUB and Kindle. Book excerpt: About the Book The book seeks to provide readers with a practical insight into provisions of FEMA and associated laws in the form of commentary. General focus of exchange control laws has gradually shifted over time to compliance, reporting and documentation. Given that FEMA provides for significant penalty and prosecution; there is little room for non-compliance. This book is an attempt to provide professionals and compliance officers with essential knowledge and tools to understand and undertake the necessary compliances. The book provides the latest position without compromising on changes in the law that have taken place over time. This book is an attempt to equip professionals, be it CS, CA, CMA or corporate lawyers, who are desirous of undertaking compliances or practicing on exchange control laws with the requisite knowledge and expertise. It seeks to be a practical guide to interpretation and compliances under exchange control laws. The book promises to be the go-to resource for exchange control laws for current and would be professionals and compliance officers. Key features Extensive coverage of FEMA and its allied rules and regulations with Commentary. Explanation of complex concepts in a lucid manner using illustrations and examples so as to provide clarity and better understanding of the law. Diagrammatic and tabular representation of various concepts for simple and quick understanding. Covering pertinent answers to issues not explicitly defined by law but clarified through practice or interpretation of the regulators. Comprehensive coverage of: (i) FEMA & Allied Acts: – Foreign Exchange Management Act, 1999 – Foreign Contribution (Regulation) Act, 1976 – Foreign Exchange Regulation Act, 1973 – Conservation of Foreign Exchange and Prevention of Smuggling Activities Act, 1974 – Foreign Trade (Development and Regulation) Act, 1992 – Prevention of Money Laundering Act, 2002 – Smugglers and Foreign Exchange Manipulators (Forfeiture of Property) Act, 1976 (ii) Rules and Regulations issued under FEMA Act, 1999 (iii) Forms (iv) FAQs issued by Reserve Bank of India (v) Press Notes (vi). Notifications issued under FEMA (vii). AP DIR Circulars (viii). Consolidated FDI Policy Circular of 2020 effective from October 15, 2020 (ix). Master Directions

Book Income Tax Act  1961

    Book Details:
  • Author : GOI. e-book compiled by Gurukripa
  • Publisher : Shree Guru Kripa's Institute of Management
  • Release :
  • ISBN :
  • Pages : 1332 pages

Download or read book Income Tax Act 1961 written by GOI. e-book compiled by Gurukripa and published by Shree Guru Kripa's Institute of Management. This book was released on with total page 1332 pages. Available in PDF, EPUB and Kindle. Book excerpt: Bare Act of Income Tax Act, 1961 updated upto Financial Year ending 31.03.2014.

Book The Law of Income Tax

Download or read book The Law of Income Tax written by Alayavalli C. Sampath Iyengar and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Book Critical Commentary on the Banning of Unregulated Deposit Schemes Act  2019 and Allied Laws  Second Edition

Download or read book Critical Commentary on the Banning of Unregulated Deposit Schemes Act 2019 and Allied Laws Second Edition written by Chaudhary Suraj Surjit and published by Bloomsbury Publishing. This book was released on 2022-02-15 with total page 520 pages. Available in PDF, EPUB and Kindle. Book excerpt: About the Book This section-based commentary attempts to highlight and analyse the various issues, problems, short-comings, lapses and merits in the Banning Act and allied laws in the backdrop of the litigation surrounding the various State/UT Acts that this new Central Act replaces. This book will be of value to anyone concerned to understand the rights and remedies under this law. This book is an exhaustive treatise on the Banning of Unregulated Deposit Schemes Act, 2019 including - - Detailed analysis of judicial precedents relating to the constitutional vires of Central Deposit Law and State Deposit Laws; - Compiles and analyses various judicial precedents relating to pari materia provisions found in State Deposit Laws; - Detailed analysis of amendments carried out in other laws, including the Securities and Exchange Board of India Act 1992, and the Reserve Bank of India Act 1934; - Detailed analysis of related laws, including the Delhi Special Police Establishment Act 1946; - Detailed analysis of priority of depositors qua the provisions of the Insolvency and Bankruptcy Code, 2016; - Covers latest developments in law including those relating to crypto-currency; - Covers the public consultation papers issued by the Central Government; and - Detailed coverage of related foreign deposit related laws, including the law of United Kingdom from where important aspects have been borrowed and incorporated in the Act.

Book Taxmann s Cross Border Transactions under Tax Laws   FEMA     Practical Commentary Enriched with   Case Laws   Judicial Interpretations   Cross References for Holistic Analysis

Download or read book Taxmann s Cross Border Transactions under Tax Laws FEMA Practical Commentary Enriched with Case Laws Judicial Interpretations Cross References for Holistic Analysis written by Dr. G. Gokul Kishore and published by Taxmann Publications Private Limited. This book was released on 2024-10-07 with total page 22 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a comprehensive guide for managing tax and compliance issues in cross-border business transactions. It focuses on critical laws such as the Income Tax Act, Customs Act, IGST Act, and FEMA, providing practical insights into international taxation, transfer pricing, and the valuation of goods in cross-border trade. The book also covers important areas like withholding tax obligations, customs duty exemptions, and the application of Double Taxation Avoidance Agreements (DTAAs). With a focus on real-world challenges, the book goes beyond basic concepts to address practical issues faced by businesses involved in cross-border operations. Its commentary is enriched with case laws, judicial interpretations, and departmental clarifications, providing a deep understanding of statutory provisions and their practical applications. Including cross-references across chapters ensures that readers gain a holistic view of the subject matter, making it a reliable tool for technical analysis and informed decision-making. This guide benefits exporters, importers, judicial members, legal practitioners, tax professionals, and government authorities. It assists these stakeholders in understanding the complexities of cross-border taxation, customs valuation, GST compliance, and FEMA regulations, helping them achieve tax efficiency and regulatory compliance. The Present Publication is the 4th Edition, amended by the Finance (No. 2) Act, 2024. This book is authored by Dr G. Gokul Kishore & R. Subhashree, with the following key highlights: • [Comprehensive Coverage of Multiple Laws] The book is unique in covering four key laws at once – the Income Tax Act, the Customs Act, the Integrated Goods and Services Tax (IGST) Act, and FEMA – making it an essential resource for understanding cross-border tax implications. It addresses areas such as arm's length pricing, Permanent Establishment (PE), intermediary services, and the role of customs authorities in regulating valuation • [Up-to-date Content] The fourth Edition is fully updated with the latest amendments as per the Finance (No. 2) Act, 2024, and includes relevant judgments and orders to ensure readers are informed of the most current legal landscape • [International Taxation & Transfer Pricing] The book thoroughly examines international taxation, covering essential topics such as transfer pricing and arm's length price (ALP) under the Income Tax Act. It analyses the complexities of associated enterprises, transfer pricing methods and judicial rulings. Additionally, the book explores the concept of marketing intangibles and AMP expenses, key challenges in Transfer Pricing (TP) assessments, and practical remedies for TP adjustments. A comprehensive analysis of the creation of Permanent Establishment (PE) is provided, with reference to relevant Double Taxation Avoidance Agreements (DTAAs) and tax treaty provisions concerning royalty, Fees for Technical Services (FTS), and tax residency • [Focus on Avoiding Profit Shifting] A key concern for tax authorities is shifting profits between jurisdictions. The book examines the Income Tax Department's focus on preventing profit shifting, especially in cross-border transactions involving payments to overseas parties, and provides strategies for businesses to remain compliant • [Customs Valuation & Compliance] The book provides valuable guidance on the valuation of imported goods under the Customs Valuation Rules, addressing challenges faced by importers and exporters when defending declared transaction values. It examines the Customs Department's concerns regarding under-valuation, especially where importers and exporters are related parties, and covers the Customs Valuation Agreement under GATT, along with judicial rulings on valuation • [GST and Cross-border Services] A crucial section is dedicated to analysing cross-border services under GST law, focusing on provisions of the IGST Act related to place of supply, export benefits, and intermediary services. The book also delves into specific challenges faced by online service providers operating across jurisdictions and how businesses can optimise compliance while leveraging export benefits under GST • [FEMA Compliance] The role of FEMA in regulating payments and receipts related to imports and exports is thoroughly discussed. It examines the intersection of FEMA with other tax laws, particularly regarding establishing branch or liaison offices of foreign companies in India. The interplay of FEMA with tax laws becomes especially significant when dealing with transactions between the establishments of the same legal entity in different jurisdictions • [Withholding Obligations & Compliance] The book provides insights into withholding obligations under the Income Tax Act, often dependent on DTAA provisions. Companies dealing with cross-border incomes like royalty and FTS must comply with these obligations, and the book provides practical guidance on how to handle such transactions effectively • [Export Promotion and Incentives] A chapter is devoted to explaining the various customs duty exemptions and export incentives available under the Foreign Trade Policy 2023, offering practical insights for companies aiming to maximise benefits through export promotion schemes • [Case Laws & Judicial Interpretations] The book stands out for its comprehensive analysis of relevant case laws and judicial interpretations. It is essential for practitioners, legal advisors, and departmental officers dealing with cross-border tax disputes. These judicial precedents help in understanding the finer nuances of the laws and their application in real-world scenarios The structure and chapter overview of the book is as follows: • Customs Valuation o This chapter explores Article VII of GATT, the Customs Valuation Agreement, and Section 14 of the Customs Act, 1962. It provides insights into customs valuation for imported goods, transfer pricing issues, and relevant judicial rulings • Transfer Pricing o A deep dive into transfer pricing rules, including international transactions, associated enterprises, and methods for determining ALP. The chapter also addresses challenges related to marketing intangibles, AMP expenses, and other TP-related issues. It also discusses secondary adjustment, Country-by-Country Reporting (CbCr), thin capitalisation, and cost-sharing arrangements • Permanent Establishment & DTAAs o This chapter covers the concept of Permanent Establishment (PE) and its treatment under various DTAAs. It discusses the attribution of profits to PE and includes judicial interpretations and ITAT rulings on the subject • Tax Residency & Withholding Obligations o Practical guidance is provided on residency, taxation of interest, dividends, royalties, Fees for Technical Services (FTS), and foreign tax credit (FTC), along with a discussion on withholding obligations under the Income Tax Act • GST & Cross-Border Services o The fifth chapter focuses on GST provisions relevant to the import and export of goods and services, with an emphasis on the place of supply and the refund mechanism under the IGST Act • Customs Duty Exemptions & Export Schemes o This chapter elaborates on customs duty exemptions and export promotion schemes available under the Foreign Trade Policy 2023 • FEMA Compliance o A concise commentary on FEMA provisions applicable to cross-border transactions, including regulations for payments and receipts in the context of imports and exports • Dispute Resolution Mechanisms o The final chapter discusses the dispute resolution mechanisms available under the IGST Act, the Customs Act, and alternative dispute resolution processes under the Income Tax Act

Book Taxmann   s Cross Border Transactions under Tax Laws   FEMA     Practical Commentary covering Income Tax  including International Tax   Transfer Pricing   GST  Customs   FEMA  etc   with Case Laws

Download or read book Taxmann s Cross Border Transactions under Tax Laws FEMA Practical Commentary covering Income Tax including International Tax Transfer Pricing GST Customs FEMA etc with Case Laws written by Dr. G. Gokul Kishore and published by Taxmann Publications Private Limited. This book was released on 2023-05-26 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides practical guidance based on judicial interpretation of the law and rules. It also provides an easy-to-understand commentary (with departmental clarifications) on cross-border transactions with respect to the following laws: • Income Tax (including International Tax & Transfer Pricing) • Goods & Services Tax (GST) • Customs • Foreign Exchange Management Act (FEMA) This book will be helpful for practitioners, members of the bar & bench and industry, and assessing officers. The Present Publication is the 3rd Edition, amended by the Finance Act 2023 and updated till 1st May 2023. This book is authored by Dr. Gokul Kishore & R. Subhashree, with the following noteworthy features: • [Easy-to-Understand Practical Commentary] covering: o Income Tax (including International Tax & Transfer Pricing) § Implications of International Transactions § Adoption of Appropriate Transfer Pricing (TP) § Comprehending the Creation of Permanent Establishment (PE) and Double Taxation Avoidance Arrangements (DTAA) § Ensuring Compliance with Withholding Obligations when payment is made to non-resident § Issues relating to Royalty & Fees for Technical Services (FTS), Tax Residency and Foreign Tax Credit (FTC) o GST § Examination of Cross-Border Services by applying Place of Supply & Export of Service provisions under the Integrated Goods and Services Tax Act (IGST), besides analyzing benefits to exporters o Customs § Valuation of Imported Goods under Customs Valuation Rules, when transaction value as declared by importer is not accepted § Availing Customs Duty Exemptions § Duty Remission and Rewards under various Export Promotion Schemes as provided in Foreign Trade Policy 2023 o FEMA § Compliance with Provisions of FEMA on Receipts and Payments for Export and Imports • [Exhaustive Discussion on both Basic Concepts and Issues faced by the Industry] combined with essential commentary on statutory provisions and the jurisprudence. • [Cross-references to other Chapters] wherever implications need to be understood The structure of the book is as follows: • [Chapter 1 | Customs Valuation] discusses Article VII of GATT, Customs Valuation Agreement, Section 14 of Customs Act, 1962, Customs Valuation Rules (for imported goods) and Export Valuation Rules with relevant judgments and orders. Pointers relating to transfer pricing issues have also been mentioned in this chapter • [Chapter 2 | Transfer Pricing] analyzes international transactions, associated enterprises, comparables, methods of determining Arms Length Price, TP challenges in India as per the UN TP Manual and judicial rulings, creation of marketing intangibles and TP issues relating to AMP expenses. TP assessment, adjustment and appellate remedy have also been included. To provide a 360° perspective, secondary adjustment, Country by Country Reporting (CbCr), thin capitalization, Cost Contribution Arrangements, intra-group services and cost-sharing arrangements have been succinctly covered • [Chapter 3 | Permanent Establishment & DTAAs] discusses taxing powers and sources of income. The concept of PE and types of PE have been explained through the relevant articles in various DTAAs, along with treatment by the Indian judiciary and ITAT. The attribution of profits to PE, which has significant practical implications, has also been discussed • [Chapter 4 | Incomes other than Business Income, Withholding Obligations and Foreign Tax Credit] is broad-based and to the extent relevant to cross-border transactions; it provides a commentary laced with practical guidance on residency, the definition of interest, jurisdiction to tax, dividends paid or received, taxation of royalty, FTS, salary, capital gains, other income, withholding obligations, FTC, the requirement to file the return and the concept of the representative assessee • [Chapter 5 | Import & Export under IGST Act] as applicable to import and export of goods, import of services and export of services, along with the provisions on the place of supply and refund mechanism, forms the fifth chapter • [Chapter 6 | Customs Exemption and Export Promotion Schemes under FTP] Considering the relevance to cross-border trade, Customs Duty exemptions and export promotion schemes under Foreign Trade Policy 2023 (FTP) have been discussed in the sixth chapter. • [Chapter 7 | Export and Import under FEMA & Regulations] Knowledge of obligations and provisions applicable to export and import under FEMA and regulations thereunder is integral to cross-border transactions. Therefore, a concise commentary on the same has been provided in Chapter 7 • [Chapter 8 | Dispute Resolution] Dispute resolution mechanisms under IGST Act and Customs Act, along with alternative dispute resolution under Income Tax Act, have been included. Chapter 8 also provides a broad overview of the statutory remedies available to exporters and importers

Book Commentary on Information Technology Act  2000

Download or read book Commentary on Information Technology Act 2000 written by Sandeep Bhalla and published by lawmystery.in. This book was released on with total page 702 pages. Available in PDF, EPUB and Kindle. Book excerpt: Facebook arrests, blocking of web sites etc. wakes up to understand what is the law behind such Government action and if it was justified. The relevant law in India is Information Technology Act, 2000. This kindle book is a legal commentary on the provisions of Information Technology Act, 2000 as enacted by the Parliament of India. This statute primarily governs the law relating to Internet, Digital Communication and other such matters. This statute covers variety of new legal rights and liabilities apart from creating various authorities for enforcement of new rights and liabilities. Certain acts have been defined as offenses which are punishable with fine or imprisonment. This book, apart from the original enacted provisions of the statute also contains legal commentary on virtually every provision to assist the the legal implications of each provision. Commentary also contains reference to existing case law on the subject without confining itself to the courts of India and incorporating judicial precedents from all over the world. Where ever direct case law is not available, an anlogous provision and case law thereon has been dealt with to thoroughly analyze the provisions of this Act. This is a 2014 edition and includes commentary on the notorious provisions introduced by Amending Act of 2008.

Book Select List of Recent Publications

Download or read book Select List of Recent Publications written by East-West Center. Library and published by . This book was released on 1963 with total page 460 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Book JAIIB Paper 4 Study Notes   Retail Banking and Wealth Management

Download or read book JAIIB Paper 4 Study Notes Retail Banking and Wealth Management written by and published by EduGorilla Community Pvt. Ltd.. This book was released on with total page 208 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Book Library of Congress Catalogs

Download or read book Library of Congress Catalogs written by Library of Congress and published by . This book was released on 1964 with total page 616 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Book Applying the Arm s Length Principle to Intra group Financial Transactions

Download or read book Applying the Arm s Length Principle to Intra group Financial Transactions written by Robert Danon and published by Kluwer Law International B.V.. This book was released on 2023-08-29 with total page 1053 pages. Available in PDF, EPUB and Kindle. Book excerpt: It is well known that intercompany financing arrangements have become increasingly subject to scrutiny in contexts of applying transfer pricing and anti-tax avoidance-related rules. With contributions by more than 50 leading global transfer pricing and international tax experts from law firms, multinational enterprises, academia, and tax administrations, this book provides unparalleled insights into the application of the Arm’s Length Principle to different types of financial transactions, application of anti-avoidance rules to various intra-group financial arrangements as well as the business value creation process and the dispute management landscape that underlie intra-group financial transactions. With in-depth analysis of the legislation and market developments that fuel the diverse range of financing options available to market participants – and loaded with practical examples and case studies that cover the legal and economic considerations that arise when analysing intra-group finance – the contributors examine such topics and issues as the following: national anti-abuse rules applicable to financial transactions; tax treaty issues; role of credit ratings and impact of implicit support; loans, cash pooling, financial guarantees; transfer pricing aspects of performance guarantees; ‘mezzanine’ financing; considerations for crypto financing; impact of crises situations such as COVID-19; how treasury operations can be structured in a group and the decision-making process involved; how hedges offset or mitigate risks; how to apply the arm’s length principle to factoring and captive insurance transactions; comparability analysis for various transactions; special considerations for transactions carried out by a permanent establishment; EU state aid and its interaction with transfer pricing rules; dispute prevention and resolution tools under the OECD, UN, and EU frameworks; and developing countries’ perspectives, focusing on Brazil, India, and South Africa. Given the challenges facing taxpayers and tax authorities alike, this book will prove an immeasurably valuable reference guide to support tax practitioners, tax administrations, and tax scholars in developing standards and policies in dealing with intra-group financing issues.