Secondary Adjustment: A Potential Wave of New Transfer Pricing Litigation

Journal
Dugar, A.; Bhandari, L.
India
Asia-Pacific Tax Bulletin 2017 (Volume 23), No. 4
FormatPDF
EUR
40
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45
(VAT excl.)

This article discusses the recent amendments to India’s Income Tax Act, which incorporate secondary adjustments into the country’s transfer pricing regime. The authors critique the language of the new statutory provisions and examine a variety of challenges to their application, which are likely to result in further transfer pricing litigation.