Mr. Akhilesh Ranjan, Joint Secretary Ministry of Finance, and
also Competent Authority for the Government of India, spoke this
past week at the Pacific Rim Tax Institute, February 19-20,
reaffirming India's commitment to a new non-adversarial tax
regime to encourage foreign investment and fair treatment of
taxpayers. Mr. Ranjan's appointment, coupled with several
key administrative enactments, signals a new positive and
cooperative attitude both to taxpayers and the larger international
tax community.
Appointed in July 2013, Mr. Ranjan replaces Mr. S.K. Mishra, the
former Competent Authority, whose insistence on the primacy of
source country rights and novel (and aggressive) interpretation of
permanent establishment rules both ostracized India from the tax
community and alienated foreign investors. It is perhaps not
coincidence that during Mr. Mishra's tenure, the number of
Indian transfer pricing controversies skyrocketed, gross domestic
product growth slowed and
