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.
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
ITR understands that UK Chancellor Rachel Reeves will announce a consultation on the proposed financial reward scheme, which had left advisers fretting