Foreword
In 2019, many countries experienced a reduction in tax base and
a decline in tax revenues due to economic developments. As a
consequence, the pressure has never been higher on tax authorities
to protect domestic tax revenues. It is not just a coincidence that
the advent of 2020 being the year of the Rat, calls for new
beginnings and brings with it a lot of expectations for prosperity
and peace. Policymakers worldwide are refining local laws, and new
fields of guidance aimed in that direction are underway.
There has been a surge of developments in the transfer pricing
space - taxation of increasing digitalized businesses, clarity on
financial transactions, etc. This transition of global business and
constant transformation is now having a perceptible effect on the
transfer pricing policy as well. While the international tax
community observed an immense load of guidelines from OECD on the
Tax front in recent times, on the other hand, the judiciary