Pre-Set Sector Pricing Idea for India: Transfer Pricing Report

Oct. 17, 2025, 9:02 AM UTC

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week practitioners in India weigh in on a government think tank’s pitch to simplify how multinationals figure out profit allocation from activities in the country and avoid lengthy court battles over permanent establishments.

Sometimes, the arm’s-length standard isn’t the best tool for the job.

At least that was the conclusion of India’s official think tank, the NITI Aayog, in a recent paper. The group is proposing to let foreign companies use predetermined government-set profit rates to help resolve arguments about taxes owed when a business has ...

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