India Transfer Pricing Changes Come With Questions, Risks

Proposed reforms to India’s transfer pricing rules would be welcome change for companies undergoing aggressive tax examinations, but could expose them to more disputes with tax authorities, according to practitioners.

While companies would get some relief by choosing the proposal for government audits of their tax positions covering three years, rather than just one year at a time, they might also be subject to more challenges from tax authorities, tax professionals said.

The three-year audit period was announced by India’s Finance Minister Nirmala Sitharaman in her budget plan for 2025.

“That obviously is very welcome for companies who are getting ...