A decennium for the Indian (Transfer Pricing) APA regime – Creating a future from learnings

Rajiv Bhutani – [2022] 138 taxmann.com 130 (Article)

Transfer Pricing has never been a static pitch and recent global trends have significantly increased the uncertainty inherent in establishing appropriate inter-company pricing. With the focus on evaluating parity between the functions performed and returns achieved by the intra-group companies, the transfer pricing provisions were introduced in India in 2001.

Over a period, the subject gained importance among key stakeholders of Multi-National Enterprises (MNEs) apart from their respective taxation departments, since it played a key role in making effective business decisions such as business expansion, making any supply chain change, ensuring compliance, or maintaining good corporate governance, etc.