A failure on the part of Indian pharmaceutical companies to keep their pricing policies in sync with the arm’s-length standard is being used by the authorities for making transfer pricing adjustments in the sector. Milind Kothari and Gaurav Shah of MZS & Associates highlight the transfer pricing traps for the industry, with the aid of recent case law.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London
India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties