International transfer pricing controversies and subsequent litigations with taxation authorities have become the major issues in foreign investments and international technology transfers. Disputes between the taxation authorities and MNCs are mounting up as most of the MNCs are now contesting...

The transfer pricing regulations in India came into force in 2001 with their effective audits beginning from the 2003 onwards. The Central Board of Direct Taxation has constituted a special cell for all transfer pricing audits. Over the past four years or so, there has been a significant...

One of the important issues in the areas of international taxation, international technology transfer and foreign investment by the MNCs that has been drawing greater attention of tax authorities worldwide is the issue of transfer pricing i.e. the compensation paid for intra-group services to...

The Government of India for the first time in 2001 introduced the transfer price regulations in the country with the transfer pricing audits effectively beginning from 2003 onwards. The onerous documentation requirements and stringent penalties prescribed by the regulations were a cause of...

Ever since the transfer pricing rules introduced in India and China they have undergone various updates based upon the requirements and need of countries and trade organisations. Concepts of the APA and SHRs have also been incorporated in their transfer pricing legislations and both countries...

The Transfer pricing rules in India which were first introduce, in the year 2001 have been regularly modified and updated and presently with the inclusion of APA and SHR system we are having the new transfer pricing regime the rules of which are at the par with most of the advance counties the...

World trade of goods and services is based upon the global supply chain and logistics management, and its flow is determined by the drivers of supply chain management. For a company to be successful in the new millennium where a paradigm shift has taken place it becomes necessary that its supply...

Introduced in 2001, transfer pricing (TP) rules in India have undergone a sea change and now with the inclusion of advance pricing agreements (APAs), safe harbour rules (SHRs) and more recent rules such as APA rollback, etc. the new TP regime is aimed to reduce litigations, provide more...

Overseas investors’ confidence is an important factor that attracts FDI. The tax and regulatory policy in the respective countries can either be a major attraction or repulsion, as far as investor sentiment is concerned. In India, this issue has had many references in the literature. To bypass...