Tuesday, 28 February 2017

India: Proposed changes to transfer pricing regulations

The recently announced Indian Budget 2017 (the Budget) proposes significant amendments to the Indian transfer pricing law.  The three key proposals of the Budget relevant to transfer pricing provisions are:

  • Introduction of a secondary adjustment mechanism. 
  • Restriction on deduction of interest paid or payable to associated enterprises (AEs) to 30% of earnings before interest, depreciation, tax, and amortisation (EBIDTA).
  • Exclusion of certain transactions from the ambit of domestic transfer pricing provisions. 

The proposals will be formalized as a part of the Indian legislation upon assent of the President of India, either in the current form or with some modifications.

Source & more info: PwC