Delhi tribunal overrules TPO to set profit split precedent

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Delhi tribunal overrules TPO to set profit split precedent

An Indian member of the EQUANT group (formerly Global One India) recently defended its application of the profit split method (PSM) against the transfer pricing officer (TPO). The ruling has provided guidance on the possible application of PSM, usually reserved for related party transactions, suggesting that it may be retroactively applicable in many international transactions.

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