 "transfer pricing provisions, associated enterprise definition, draft Income Tax Bill 2025, beneficial ownership tax rule, intra-group transactions India, house property income taxation, pre-construction interest deduction, Income Tax Act associated e")
Taxpayers — typically foreign companies — seeking to appeal excess tax demands through a key dispute resolution mechanism face longer timelines in India than in many peer economies.
Transfer pricing cases under the mutual agreement procedure (MAP) take an average of 35.8 months to close in India, according to the latest international data (2023) from the Organisation for Economic Co-operation and Development (OECD). Comparable timelines range from 19.3 months to 29.3 months in countries such as China, the US, Germany, South Africa, and Japan. India also handles a relatively high number of such cases.
Transfer pricing
