Desideratum for HR Excellence and Skills for New International Transfer Pricing Regime

In consonance with globalization, the International Transfer Pricing (ITP) rules have also been introduced in the countries, where they did not exist, or reformed as per the OECD guidelines in a number of countries where they already existed. In many countries the process of revamping these rules is still in process and existing rules are being reviewed and modified continuously for their effectiveness. In India, these rules were first introduced in 2001, and since then have been continuously being upgraded with the adoption of new provisions such as advance pricing agreements (APAs), Safe Harbour Rules (SHRs), Roll Back Provision in APA system, Tuning the existing rules in line with the BEPS, etc. and today country offers one of the best ITP regulations amongst the developed world. Nevertheless, for the effective implementation of the New International Transfer Regime, one of the major concern has been a required manpower with skills to deal with the related issues. To address this concern, and create awareness amongst the young graduates in this field, this paper first attempts to discuss some of the basic concepts and then spells out the desideratum (need) of human resources in this crucial area of international taxation and business