Transfer Pricing (Domestic & International Transactions) (8th Edition, 2026)
- Year of Publication: 2026
- Edition: 8th
- ISBN: 978-81-69449-21-2
- No.of Pages: 1752
Transfer pricing today stands as one of the most formidable pillars of international taxation. The evolving landscape of the global economy is characterised by significant reconfiguration of global value chains not only due to the quest of various Governments to attract capital formation and generate employment but also due to various disruptions such as covid, war, weaponisation of international waters etc. Governments are now offering targeted incentives for re-shoring and localising key functions. The United States, under recent policy direction, has encouraged a pivot away from Chinese manufacturing dependencies in favour of domestic production. India, too, seeks to establish itself as the next best alternative to China in the global manufacturing ecosystem and has entered into multiple high value FTAs such as the one with EU, which is expected to significantly enhance the number of MNEs venturing into India. On the other hand, the fast evolving space of AI has also raised concerns about sovereignty resulting in Governments pursuing self reliance both in the case of chips and data centres. New safe harbour provisions have been introduced to facilitate some of these. The existing transfer pricing policies have to be revisited in the light of this evolving landscape. These structural shifts will naturally compel multinational enterprises (MNEs) to re-align their operational footprints, rethink supply chain logistics, and reallocate their key functions in a manner that balances commercial viability with tax and regulatory efficiency.
This evolving global landscape reinforces a fundamental idea that has increasingly shaped our thinking over the years—tax is not a burden to be minimised, but a system to be understood and aligned with. When business objectives are aligned with national priorities, taxes cease to be a cost and instead become a source of opportunity. This philosophy, which we describe as Tax as Profit™, encourages taxpayers to move beyond reactive compliance toward proactive alignment — where structuring decisions are guided not only by efficiency but by a deeper understanding of the intent embedded within tax systems.
On the domestic tax front, the new Income Tax Act, 2025 proposes to increase the scope of transfer pricing with a significant amendment to the definition of “associated enterprise”. The impact of this would be felt in the Tax Year 26–27 as the Act comes into force on 01.04.26 and is expected to be tested in the courts and would be one of the important issues to watch out for. Though the Act comes into effect from Tax Year 26-27, the new Income Tax Act, 2025 has been kept as the base and the section numbers pertaining to the 1961 Act have been given as reference at all places in the book.
In this edition of the book, case laws – including landmark Supreme Court and international decisions – are now integrated into the respective thematic chapters along with commentary from the OECD and UN Transfer Pricing Guidelines, allowing for seamless reading and deeper contextual understanding. A synopsis of UAE transfer pricing regulations has also been included
Sundara Rajan leads the International Tax and Transactions practice at DVS. He is a Chartered Accountant with more than a decade of experience in International Tax, FEMA and Mergers. He is an active researcher in the space and regularly contributes to leading media houses on the subject. Sundar works closely with leading corporations in FMCG, Automobile, Textile, IT industry, etc and has been consistently recognised by his clients for his clarity of thought and ability to break down complex problems. Prior to this stint, Sundar was into credit underwriting and has underwritten over Rs. 5000 crores of SME retail book across Southern India for leading NBFCs.
Bharat is a 'trade-name' for a group of concerns, popularly known as Bharat Law House and Bharat Law House Pvt. Ltd. Bharat is one of the most reputed publishers of law books with an experience of over six decades. It possess a very diverse range of publications covering not only the area of taxation - direct and indirect - but also company law, insolvency capital market, finance, industrial law, foreign exchange, commercial, civil and criminal laws. The students publications for CA, CS, CMA, CFA, MBA, graduate and post-graduate studies have carved out a niche for themselves. The Publication House has a professionally qualified team with strong in-house capabilities. Their strength lies in the patronage of legal luminaries in every field. They strive for accuracy, authenticity and sincerity.
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- Year of Publication: 2026
- Edition: 8th
- ISBN: 978-81-69449-21-2
- No.of Pages: 1752
Transfer pricing today stands as one of the most formidable pillars of international taxation. The evolving landscape of the global economy is characterised by significant reconfiguration of global value chains not only due to the quest of various Governments to attract capital formation and generate employment but also due to various disruptions such as covid, war, weaponisation of international waters etc. Governments are now offering targeted incentives for re-shoring and localising key functions. The United States, under recent policy direction, has encouraged a pivot away from Chinese manufacturing dependencies in favour of domestic production. India, too, seeks to establish itself as the next best alternative to China in the global manufacturing ecosystem and has entered into multiple high value FTAs such as the one with EU, which is expected to significantly enhance the number of MNEs venturing into India. On the other hand, the fast evolving space of AI has also raised concerns about sovereignty resulting in Governments pursuing self reliance both in the case of chips and data centres. New safe harbour provisions have been introduced to facilitate some of these. The existing transfer pricing policies have to be revisited in the light of this evolving landscape. These structural shifts will naturally compel multinational enterprises (MNEs) to re-align their operational footprints, rethink supply chain logistics, and reallocate their key functions in a manner that balances commercial viability with tax and regulatory efficiency.
This evolving global landscape reinforces a fundamental idea that has increasingly shaped our thinking over the years—tax is not a burden to be minimised, but a system to be understood and aligned with. When business objectives are aligned with national priorities, taxes cease to be a cost and instead become a source of opportunity. This philosophy, which we describe as Tax as Profit™, encourages taxpayers to move beyond reactive compliance toward proactive alignment — where structuring decisions are guided not only by efficiency but by a deeper understanding of the intent embedded within tax systems.
On the domestic tax front, the new Income Tax Act, 2025 proposes to increase the scope of transfer pricing with a significant amendment to the definition of “associated enterprise”. The impact of this would be felt in the Tax Year 26–27 as the Act comes into force on 01.04.26 and is expected to be tested in the courts and would be one of the important issues to watch out for. Though the Act comes into effect from Tax Year 26-27, the new Income Tax Act, 2025 has been kept as the base and the section numbers pertaining to the 1961 Act have been given as reference at all places in the book.
In this edition of the book, case laws – including landmark Supreme Court and international decisions – are now integrated into the respective thematic chapters along with commentary from the OECD and UN Transfer Pricing Guidelines, allowing for seamless reading and deeper contextual understanding. A synopsis of UAE transfer pricing regulations has also been included
Sundara Rajan leads the International Tax and Transactions practice at DVS. He is a Chartered Accountant with more than a decade of experience in International Tax, FEMA and Mergers. He is an active researcher in the space and regularly contributes to leading media houses on the subject. Sundar works closely with leading corporations in FMCG, Automobile, Textile, IT industry, etc and has been consistently recognised by his clients for his clarity of thought and ability to break down complex problems. Prior to this stint, Sundar was into credit underwriting and has underwritten over Rs. 5000 crores of SME retail book across Southern India for leading NBFCs.
Bharat is a 'trade-name' for a group of concerns, popularly known as Bharat Law House and Bharat Law House Pvt. Ltd. Bharat is one of the most reputed publishers of law books with an experience of over six decades. It possess a very diverse range of publications covering not only the area of taxation - direct and indirect - but also company law, insolvency capital market, finance, industrial law, foreign exchange, commercial, civil and criminal laws. The students publications for CA, CS, CMA, CFA, MBA, graduate and post-graduate studies have carved out a niche for themselves. The Publication House has a professionally qualified team with strong in-house capabilities. Their strength lies in the patronage of legal luminaries in every field. They strive for accuracy, authenticity and sincerity.
