The OECD has released a white paper on transfer pricing documentation, which proposes a two-tier approach that would require taxpayers to submit a global master file along with country-specific transaction information. However the proposals could result in an increased compliance burden for businesses, according to one revenue authority official.
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