The Indian transfer pricing regulations are expected to provide a more robust framework for taxpayers and the revenue authorities alike to demonstrate the arm’s-length character of their related-party transactions. However, Amit Agarwal of Ernst & Young argues that the wide discretion conferred on the revenue authorities in the interpretation and implementation of these regulations has spawned a cesspool of tax controversies leading to substantial tax adjustments. It is reported that in the latest round of transfer pricing audits the cumulative value of these adjustments was $8.9 billion.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Complex and constantly shifting rules on global mobility mean ‘the risk is too great’ for staff to work abroad on personal time, EY’s Maureen Flood tells ITR
While it’s great that the OECD is alive to multinationals’ fears of being caught in a compliance trap, the ‘common understanding’ illustrates a worrying lack of readiness
Rising demand for specialist expertise has fuelled the growth in tax partner headcounts, Cain Dwyer found; in other news, Switzerland has been urged to reconsider pillar two
Trophy assets are evolving from personal indulgences to structured investments, prompting family offices to prioritise tax efficiency, governance discipline, and cross-border compliance
Jurisdictions have moved to ensure that multinationals are not punished for late GIR filings due to a lack of available filing portals or exchange relationships
HMRC’s push for unified tax adviser registration won’t prevent every instance of improper conduct, but it is good for taxpayers and the UK’s reputation