The new three-tier documentation structure for transfer pricing aims at providing access to the revenue authorities on information pertaining to operations of multinational enterprises. Accordingly, a three-tier documentation structure was recommended for transfer pricing. Although “substance over form” has always been the guiding principle for any transfer pricing analysis in India, the new BEPS regime has further brought it into limelight. The revised transfer pricing documentation structure has been created as one of the enablers to achieve this objective. Intra-group agreements often serve as the starting point for a transfer pricing analysis.

Source: Mint March 22, 2018 23:37 UTC