Transfer pricing in India has also seen humongous amount of litigation in the area of Comparability Analysis, risk related issues, Arm’s Length Range, TP Adjustment, Location Savings, Intangibles, R&D activities, financial transactions and Intra-group services.
Lately there has been a great emphasis on reduction of litigation, with both Tax payers and the revenue authorities being involved on confidence building measures and regulations such as APA’s, safe harbors and dispute resolution panel being introduced to mitigate the unnecessary litigation and uncertainties in the transfer pricing regime.
India has been closely observing OECD’s BEPS initiatives and is likely to come up with its own guidance in the short future for implementing international measures that will promote tax transparency for all stake holders.
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