Emerging Transfer Pricing and International Tax Issues

While recent audits in India have seen transfer pricing adjustments relating to share valuation by companies in related-party transactions (Shell India case) and the tax treatment of contract R&D centres in the IT sector (Microsoft India case), other international tax issues like the treatment of royalties for software use (Nokia India case) and the out-of-court conciliation process (Vodafone case) also attracted considerable attention in 2013. The author considers these emerging issues in the context of transfer pricing provisions and international taxation in India, and suggests a possible course of actions on the basis of his analysis.