Article
India Transfer Pricing & Permanent Establishment Disputes: Characterisation, Profit Attribution And Litigation Strategy
Within most multinational groups, transfer pricing is still perceived primarily as a technical compliance function. It is frequently treated as a year-end margin exercise — a benchmarking study intended to ensure that operating profit falls within a statistical range. Boards often view it as a documentation issue, while finance teams approach it as a provisioning variable.
R & D Law Chambers LLP