Tag: Transfer Pricing
Browse our exclusive articles!
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.
When AMP Spend Does – And Does Not – Look Like a Marketing Intangible Issue
Local marketing spend in India often sits inside routine distribution economics. The harder question is whether the taxpayer can prove who controlled that spend, who bore the risk, and who kept the commercial upside.
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.
Tax certainty India: Board for Advance Rulings vs MAP vs APA – what corporates should choose now
India's tax-certainty architecture now rests on three very different routes. BAR offers domestic legal clarity, MAP delivers treaty relief, and APA has become the most institutionalised option for recurring transfer-pricing risk. The right choice depends on timelines, bilateral exposure and how much confidentiality a boardroom really needs.
Capital vs revenue in digital businesses: when old doctrines meet the cloud invoice
Capital vs revenue lines are fraying in India’s digital economy. SaaS subscriptions, cloud infrastructure, and data-driven intangibles create enduring benefits without durable assets, forcing doctrine to chase new facts
