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As the Modi Government prepares to present its last complete budget before the 2019 general elections, we reflect on the current fiscal year and evaluate the key target areas for the financial and tax reform proposals of ‘Budget 2018'.

"Vasudha-Iva Kutumba-Kam (Sanskrit: वसुधैव कु टुम्बकम) - The Whole World is ONE FAMILY." The phrase has become most relevant in reference to present day world economics.

For multinational companies with established GCCs in India, profit repatriation is a natural extension of a successful operating model. When approached strategically, it allows businesses to optimize global cash flows while remaining aligned with India's tax and FEMA regulations.

Starting from The United Nations Framework Convention on Climate in 1992, Kyoto Protocol in 1997, L 'accord de Paris in 2015, COP 26 in Glasgow 2021 and COP 27 in Egypt 2022...

Kolkata Tribunal Special Bench Ruling – Whether an arm's length price adjustment was required to be made in respect of interest free loan granted by the assessee, a non-resident company, to its wholly owned subsidiary in India?

As global capabilities center transition from basic tasks of IT support to advanced innovative technology hubs characterized by AI model training & use of evidence-based research & development, this blog discusses how such functions must be evaluated for purposes of transfer pricing, issues regarding DEMPE, and documentation gaps that and contribute significantly to disputes.

Macrotech Developers Limited (Known by the brand name ‘Lodha' and hereafter referred to as the ‘taxpayer') is an Indian company engaged in the business of building and developing residential and commercial properties.

Transfer pricing regulations adopted by India are based on the arm's length principle which revolves around the concept that the price or margin determined in a controlled transaction...

An important change brought about vide the Notification is the application of thresholds for the number of investors and investment on a ‘look through' basis in case of a pooling vehicle being the investor in the fund.

For offshore subsidiaries operating in India, transfer pricing compliance is not an optional exercise — it is a statutory requirement under the Income Tax Act, 1961.

It is oft said that statutes are many spender things – they are so tightly and precisely defined, that the Judiciary's predictive task is quite straightforward.

In my earlier article, I looked at whether a Global Capability Centre (GCC) can create a permanent establishment (PE) in India for its foreign parent. The short answer was that it can, but only where the facts show that the parent itself is carrying on business through the Indian centre. The question I am asked next, almost every time, is a practical one: what should we actually do about it?

Many multinational groups now run a good part of their research and development from a global capability centre (GCC) in India. The engineering work gets done, the product gets built, and then a simple question comes up that nobody had planned for: who actually owns the intellectual property (IP)? In my experience advising on such structures, this question is usually asked late, often during a funding round, an audit or a dispute. By then, fixing the paper trail is expensive.

The arm's length principle is the international standard for determining the taxability of profits resulting from transactions between related entities.

Multinational Enterprises ("MNEs") set up subsidiaries in India to cater to the Indian market and capitalize on their brands.

India is still a maturing tax jurisdiction especially on the international taxation front. The Indian tax landscape has been fraught with multifarious and protracted litigation...

The Income-tax Act, 2025 introduces significant amendments to India's transfer pricing regime, fundamentally restructuring how associated enterprise relationships are determined and expanding the scope of international transactions subject to arm's length pricing requirements.