Effective transfer pricing is essential for multinational corporations to align tax strategies, comply with regulations, and ensure fair profit allocation among global entities. By adopting arm’s length pricing and maintaining transparent documentation, MNCs can optimize cash flows, reduce tax risks, and support strategic decisions across supply chains. Proper transfer pricing not only enhances operational efficiency and competitiveness but also minimizes disputes with tax authorities.
The APA regime has significantly strengthened India’s transfer pricing framework by enhancing certainty and reducing litigation. However, challenges remain—such as the limited uptake of unilateral APAs. To fully realize its potential, reforms aimed at boosting efficiency, transparency, and fairness are essential. Strengthening the APA system will not only help resolve tax disputes more effectively but also create a stable and attractive environment for multinational companies seeking long-term.
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