A campaign is building for the introduction of the inter-quartile range, and the acceptance of multiple year data, for transfer pricing documentation in India – a country that goes against the global best practice. Indian transfer pricing regulations are unique in the sense they require the computation of a single arm’s-length price, through the mean of comparables, instead of a range. Tax practitioners are not interested in being unique though. Sophie Ashley finds out why.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default
Despite legislative gridlock, international investors should be wary of legal precedents set by recent court rulings, which could substantially alter the Spanish tax environment