Tag: International Tax
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Mutual Agreement Procedure as Strategy: Why Waiting Too Long Blunts Competent Authority Relief
Mutual Agreement Procedure is increasingly central to India's tax-certainty architecture. The real strategic mistake in 2026 may not be using MAP - it may be using it too late.
Transfer Pricing True-Ups at Year-End: Commercial Hygiene or Audit Trigger by Design?
Transfer pricing true-ups are not inherently suspect. But in India, a year-end margin correction becomes defensible only when contracts, monitoring, settlement and Rule 10D evidence all point to one coherent pricing policy.
Intra-group services: India’s benefit-test obsession is becoming a tax-certainty problem
India's transfer pricing fights over intra-group services have become too fixated on proving 'benefit' after the fact. A better test would ask what service was actually rendered, why it was needed, and whether it was priced credibly.
DEMPE Analysis Is Turning Formulaic—and That’s Becoming a Transfer Pricing Risk
DEMPE analysis is becoming harder to fake. As transfer pricing audits mature and routine disputes get simplified, template-heavy intangible files are increasingly exposed as evidence-light and adjustment-prone.
MFN clause after Nestlé: treaty shield or drafting illusion?
MFN clause disputes in India are no longer a technical footnote. Recent rulings, a 2025 tribunal order, Switzerland’s reset and France’s 2026 rewrite show why treaty parity now turns on wording, timing and notification discipline.
