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Outsourcing and Transfer Pricing — The Challenges

Volume 19, Number 3 Article by Suveera Gill September, 2007

Outsourcing and Transfer Pricing — The Challenges :

Global competition for resources, markets and efficiencies continues to drive cross border flow of goods, services and capital. As investment becomes increasingly mobile and multinational enterprises (MNEs) expand their global supply chains, competition for investment and taxes is driving more legislation and enforcement by taxation authorities. One of the most daunting tasks faced by MNEs is the determination of prices at which physical goods and services are traded between associated enterprises — commonly referred to as transfer pricing (TP). With ever increasing outsourcing and the introduction of TP rules and regulations by more countries, enterprises are subject to conflicting rules and double taxation. The TP Directorate in India which carried out its first audit in 2005 has already identified 250 companies for Rs 1,250 crores of additional tax for their cross-border transactions. A slew of multinationals cutting across sectors have contested demands raised on them for violations of TP norms. Suveera Gill traces differences in transfer pricing among selected countries and scrutinises the decisions on various TP cases in India so as to identify the taxation issues which need to be addressed.

The findings of the paper highlight the considerable differences in TP regulations, practices and approaches followed by India and the top nine foreign direct investor countries in India; the ambiguities and uncertainties in the Indian transfer pricing realm on account of the lack of a centralised approach to revenue audits and dearth of case laws passed under the new transfer pricing regulations. Lastly, India does not take recourse to the advance pricing agreements mechanism of dispute resolution

The paper concludes by recommending a review of some of the contentious transfer pricing issues by the authorities and that MNEs should formulate coherent transfer pricing policies that are applied consistently across the globe and are supported by robust, well coordinated documentation.

Reprint No 07306