An Introduction to Transfer Pricing

After the fourfold increase in ease of facilitating business beyond the borders of any nation, the rules

for transfer pricing are highly important in nature for all large-scale global businesses. Transfer

pricing has become highly crucial to ensure fair and equitable distribution of profits while complying

for tax regulations. The Transfer Pricing (TP) Regulations were introduced in India in the year 2001,

in order to prevent erosion of Indian tax base. The Indian TP Regulations are contained in Chapter X

of the Income-tax Act, 1961 (“the Act”) under the title “Special Provisions relating to avoidance of

tax”. In 1990s, India’s former finance minister introduced new reforms for more opening of the

Indian economy thus opening up our borders to a more business conducive environment from all

around the globe. This led to an increase in the interests from the FDI from MNCs. The general rules

and regulations are generally based on OECD (Organisation for Economic Co-operation Development

Guidelines. There are various guidelines given which prescribe different transfer pricing methods,

the principle of ALP and the documentation requirements as well as the tax procedures and

compliances requirements.

Navigating the complex arena of transfer pricing regulations is one of the most important tasks for

any organisation to go global. Hence, we bring to you some innovative insights to guide you through

the same.

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