India
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
India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties
Booming APA statistics reflect the growing credibility of India’s TP framework and the country’s shift toward a tax certainty approach, ITR has heard
Authors from Khaitan & Co evaluate the recent CBDT notification, whereby legacy investments made by investors continue to be exempt from the applicability of GAAR
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Sponsored by Deloitte Transfer Pricing GlobalEdward Morris and Jamie Hawes of Deloitte discuss how the resolution of controversy has changed with the introduction of a more efficient system to handle MAPs and APAs. -
Sponsored by Deloitte Transfer Pricing GlobalJuan Ignacio de Molina and Christine Ramsay of Deloitte consider the increased reliance of tax authorities on CbCR data and how the data reported in the CbCR during the COVID-19 pandemic could impede its use.
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Sponsored by Deloitte Transfer Pricing GlobalShaun Austin, Richard Schmidtke and Aparna Rao of Deloitte discuss the challenging transfer pricing concepts of intangibles arrangements and important regulatory changes from Australia and Germany.
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