13 March 2013
Economy
Expert Speak
Interpreting 'Transfer Pricing' rules in India
Evolving rules; APA mechanism holds promise; Belt tightening world over
The issue of transfer pricing has hit headlines in recent times with a rising number of disputes
involving frontline domestic and international companies. For a perspective on this issue, we
organized a concall with two luminaries in the area of transfer pricing and international taxations,
Mr Mukesh Butani and Mr Amod Khare, from BMR Advisors. We present the key takeaways.
Indian Transfer Pricing laws based on OECD guidelines; Belt tightened elsewhere too
Indian transfer pricing (TP) laws are based on OECD guidelines which too are evolving.
Seen simply, transfer pricing laws prevent shifting profits from high tax jurisdiction to a
lower one.
Indian TP laws are operational since 2001 that defines its applicability.
While a host of TP issues has affected companies and investors, belt tightening on TP laws
in recent years is a worldwide phenomenon.
Devil is in the detail - specifics of India
Indian laws have detailed guidelines to determine the Arm's Length Price (ALP) based on
five methods.
However, normally it is the Transactional Net Margin that is most widely used. It involves
comparison of the margin earned by the tax payer vis-à-vis the net margin earned by
comparable companies under similar circumstances.
The laws also prescribe procedures for the tax payer and tax department to compute tax
liability and demand, respectively.
A detailed process of remedy for tax payers with various layers of appeal is also possible
under the law.
Disputes due to interpretation of economics, laws, implementation
As TP becomes important as a source of revenue, there are increased disputes.
In most cases it is the differing perspectives on the economic basis of transactions that
result in disputes.
Thus, the choice of comparables to determine the Arm's Length Price (ALP) becomes the
key issue to the dispute.
Lagged enactment of the law and proactive tax officials have increased the incidence of
disputes.
This has resulted in a pile-up of disputed cases.
Way forward - APA mechanism holds promise
The Advance Pricing Agreement holds the promise of a true game changer. This is an
agreement that the tax payer enters with the Advanced Pricing Authority and it broadly
ensures that the transfer prices worked out are not questioned again by the tax
administration.
The 2012 changes in the Dispute Resolution Panel (DRP) rules, that makes it more even by
allowing appeal by the tax department too, hold the promise of faster and more balanced
orders (earlier only the tax payer was allowed to appeal thus making DRP biased towards
the tax department).
Besides, tax payers need to be cautious and maintain a checklist.
As a specific example, the Vodafone issue is likely to be settled with some compromise.
Incidentally, the Finance Minister in his post policy media interactions highlighted that the
offer of conciliation from Vodafone is under Cabinet's consideration.
Mr Mukesh Butani
Mr Mukesh Butani is an
acclaimed expert in the
areas of international tax
transfer pricing and Indian
tax & regulatory policies.
He has significant
experience in advising
Fortune 500 multinationals
and Indian business
houses. He is associated
with numerous national
and international tax
bodies and is a member of
the Advisory Group on
International Tax and
Transfer Pricing constituted
by the Indian Ministry of
Finance.
Mr Amod Khare
Mr Amod Khare is a partner
in the firm's Direct Tax and
Transfer Pricing practice.
Previously he was with
Ernst & Young and
Andersen. He has
significant experience in
advising clients in the
media and entertainment
industry on tax, transfer
pricing and regulatory
issues.
Dipankar Mitra
(Dipankar.Mitra@MotilalOswal.com); +91 22 3982 5405
Investors are advised to refer through disclosures made at the end of the Research Report.
1

Expert Speak
Indian Transfer Pricing laws based on OECD guidelines
Belt tightened elsewhere too
Indian transfer pricing (TP) laws are based on OECD guidelines which too are evolving.
Seen simply, transfer pricing laws prevent shifting profits from high tax jurisdiction to a
lower one.
Indian TP laws are operational since 2001 that defines its applicability.
While a host of TP issues has affected companies and investors, belt tightening on TP laws
in recent years is a worldwide phenomenon.
,,
,,
Transfer pricing laws
essentially prevent a
transfer of profits from a
high tax jurisdiction to a
low tax one. The Indian
transfer pricing guideline
are comparable or
similar to the OECD
guidelines.
OECD - precursor to Indian TP laws:
The Indian TP guidelines are comparable or similar
to the OECD transfer pricing guidelines. OECD announced a vital project called "Base
Erosion and Profit Shifting." BEPS is a constructive dialogue between the government
and tax payers on transfer pricing issues and on complex issues that arise from transfer
pricing.
Aim of TP laws:
It essentially prevents a transfer of profits from a high tax jurisdiction
to a low tax jurisdiction. Illustrations include the US Congressional enquiries against
large multinationals, including Google and Starbucks.
TP laws operational since 2001 in India:
The law existed for many years in the Western
countries and was brought into the Indian statute only in 2001 as the majority view
held it was premature to have it in India. But having lived with the law for almost 12
years, the realization is that a bit of ground work should have been done.
Applicability well-defined:
The laws define when transfer pricing should apply, who
are associated enterprises and their relevance; whether the transaction is undertaken
between associated enterprises and when it would be subject to the rigors and
compliance of transfer pricing. The laws also define what is an international transaction
and cover certain artificial situations to treat two independent parties as being related.
Impact of TP laws:
Broadly it impacts two groups: i) tax payers (direct impact on
increasing bottom line) and ii) investors (made foreigners cautious on India, concerns
of other governments).
Belt tightening happening across the globe:
The process of belt tightening started
immediately with G20's communiqué, post 2008 economic crises. Now difficult
questions arise on jurisdiction of the related parties and eyebrows are raised if you
come from a jurisdiction which is a tax haven or relatively low tax country. The
exchange of information and surveillance that tax authorities have are higher within
countries that do not have a tax treaty. For example in 2006, despite being a country
with a very stable regime and relatively low tax rate, Singapore went ahead to issue
the transfer pricing guidelines (although not a law). Hence, documentation needs to
be maintained and based on the functions performed, companies resident in Singapore
pay taxes so that it does not give an opportunity for other countries to raise issues
about Singapore. Thus, the general level for concern on transfer pricing is very high in
each jurisdiction. Another point is that 10 years ago, besides Australia, Japan and
perhaps South Korea, there was no transfer pricing legislation in Asia. Presently, 90%
of the countries in Asia are covered by the transfer pricing regime.
2
,,
10 years ago, besides
Australia, Japan, and
perhaps South Korea,
there was no transfer
pricing legislation in
Asia. Today, 90% of the
countries in Asia are
covered by the transfer
pricing regime.
,,
13 March 2013

Expert Speak
Devil is in the detail
Specifics of India
The most widely used
method for computation
of Arm's Length Price
(ALP) is the Transactional
Net Margin method that
involves comparison of
the margin earned by the
tax payer vis-à-vis the
net margin earned by
comparable companies
under similar
circumstances, with
respect to a similar
transaction.
Indian laws have detailed guidelines to determine the Arm's Length Price (ALP) based on
five methods.
However, normally it is the Transactional Net Margin that is most widely used. It involves
comparison of the margin earned by the tax payer vis-à-vis the net margin earned by
comparable companies under similar circumstances.
The laws also prescribe procedures for the tax payer and tax department to compute tax
liability and demand, respectively.
A detailed process of remedy for tax payers with various layers of appeal is also possible
under the law.
,,
,,
,,
Five ways to determine Arm's Length Price:
The rules explain how transfer pricing
adjustments need to be done by using the prescribed methods to determine the
Arm's Length Price (ALP). The Income Tax rules prescribe five detailed methods and a
summary method in case the other five methods are not found to be appropriate.
Normally, the preferred method to determine the ALP is the "Comparable
Uncontrolled Price" method also referred to as CUP method. In India, in the absence
of an appropriate CUP, the tax payer and tax administration normally refer to what is
known as a "Transactional Net Margin" method. This method involves comparison of
the margin earned by the tax payer vis-à-vis the net margin earned by comparable
companies under similar circumstances with respect to a similar transaction. The
choice of methodology is left to the tax payer; however, the Indian tax administration
has the power to reclassify or re-determine the appropriate method if they believe
the method used by the tax payer is not appropriate.
Five steps to determine ALP:
Steps include i) selection of appropriate transfer pricing
methodology, ii) identification of the tested party (the party vis-à-vis whom the
comparable companies will be tested), iii) identify a profit level indicator (for
comparing the profit ratio of tax payer with the profit rate of the comparable
companies), iv) search for comparables (use of Prowess or Capitaline database) - the
search is part of the documentation that the tax payer maintains and v) computation
of ALP.
Tax department's process of raising demand, if any:
This involves the following steps:
i) Assessing officer (AO) refers the matter to Transfer Pricing Officer (TPO) of the
Transfer Price Wing of the Income Tax Department if the value of transaction exceeds
INR150m, ii) the TPO will then issue a notice to the tax payer asking him to defend its
ALP, evaluates response of the tax payer, iii) TPO passes an order establishing what
according to him should be the ALP and determines the transfer pricing adjustment,
iv) assessing officer (AO) then incorporates the TPO order into his own and a demand
is raised on the tax payer through a draft assessment order.
Remedy available to the tax payer:
The tax payer can either escalate the dispute to
the Dispute Resolution Panel (DRP) or refer the dispute to the Commissioner of Income
Tax Appeals (CIT). Once the DRP passes an order, the AO passes his final assessment
3
The Indian tax
administration has the
power to reclassify or
redetermine the
appropriate method if
they believe the choice
of method used by the
tax payer is not
appropriate.
,,
13 March 2013

Expert Speak
,,
Can the matter can be
taken to the high court or
the Supreme Court is
determined by whether
the dispute involves a
question of law or is it
only a question of fact.
,,
order. The final assessment order forms the basis of appeal to CIT and thus AO issues
it even in cases where the tax payer appeals the matter directly to CIT or as in the
earlier case when the appeal is routed through ARP first. Once the tax payer has the
order of the Commissioner of Income Tax Appeals, he can then refer the dispute to
the Income Tax Appellate Tribunal. And in contrast, if the tax payer had gone before
the DRP, he can approach the Income Tax Appellate Tribunal on receipt of the final
order from the assessing officer. The process of appeal thereafter is similar to what
happens in corporate tax appeals -- after the appellate tribunal, the tax payer can go
to the High Court and thereafter the Supreme Court. But whether the matter can be
taken to the High Court or Supreme Court is determined on the basis if the dispute
involves a question of law or it is only a question of fact.
Fairly elaborate process of remedy available under Indian tax laws
Strict documentation and penalty clauses:
For transfer pricing purposes, tax payers
also need to file an accountant certificate that discloses the details of all international
transactions undertaken by the tax payer for that year and it is a certificate which also
comments on the appropriateness of the ALP. There are strict norms for documentation
covering international transactions and penalties prescribed for non-submission.
13 March 2013
4

Expert Speak
Disputes are rising
Interpretation of economics, laws and implementation differ
As TP becomes important as a source of revenue, there are increased disputes.
In most cases it is the differing perspectives on the economic basis of transactions that
result in disputes.
Thus, the choice of comparables to determine the Arm's Length Price (ALP) becomes the
key issue to the dispute.
Lagged enactment of the law and proactive tax officials have increased the incidence of
disputes.
This has resulted in a pile-up of disputed cases.
,,
,,
The quantum of
adjustments that have
been undertaken by the
tax administration is
expected to be USD15b
this year.
,,
An important source of revenue:
As transfer pricing becomes important as a source of
revenue, it has increased the number of disputes. In the first round of transfer pricing
audits concluded in 2004, there was a cumulative value of adjustments of USD0.5b.
Last year, though the adjustment reached USD12b, this year it is expected to be USD15b.
"Adjustments" mean the quantum of adjustments that have been undertaken by the
tax administration as far as the transfer pricing audits are concerned.
Embedded economic analysis makes transfer pricing disputes special: It
also includes
a reference to the economic analysis that needs to be undertaken by the tax payer.
The economic analysis has been the basis for establishing that the tax payer has
undertaken the transaction at an appropriate or ALP. The reason why a transfer pricing
dispute is different is since one looks at the disputes that arrive out of an economic
theory. For example, to what extent functions were performed in India, risks were
assumed in India, assets were located in India; many of these factors become a part of
the economic theory. To what extent economic adjustments have to be allowed when
one is comparing himself with a similar transaction is also a part of the economic
theory.
Areas of dispute in India:
Many cases of transfer pricing have erupted in the last four/
five weeks including Maruti Suzuki, LG Electronics, Hindalco, Asian Paints, Indo-
American, Shell, Ascendus etc, reflecting the belt tightening by Indian authorities.
The broad reasons for such transfer pricing issues revolve around the choice of
comparables; e.g., i) validity of the comparables, ii) adjustments undertaken, iii)
filters used (turnover filter or related party filter), iv) single year or multiple year
data, v) treatment for segmented businesses, vi) tested party etc.
Ambiguous laws v/s arbitrary implementation:
The primary reasons for the prevailing
state of affairs are mainly four. First, we are dealing with a backlog of 10-year cases
due to delayed enactment of the law and most cases pertain to last four years which
could have been averted if we had an APA mechanism established already. Secondly,
we are attempting a transition from OECD model to UN model in accordance with
non-OECD countries that emphasizes strict source based taxation. Third, this has
turned out to be potentially vital source of revenue for India. Lastly, tax officials
chasing targets rarely accord the benefit of doubt to the tax payer.
A backlog of cases due to
delayed enactment,
transition to UN model
from OECD model and
tax officials chasing
revenue targets are
responsible for large
number of disputes.
,,
13 March 2013
5

Expert Speak
,,
,,
As matters pile up
before various tribunals
on resolution of dispute,
it is a concern not just for
tax payers but even for
the government.
,,
Pace of dispute resolution:
As matters pile up before various tribunals for resolution
of disputes, it is a concern not just for tax payers but even the government. Though
disputes' resolution is not very slow, it will get slower in the future given the unabated
amount of adjustments that are taking place. If one has a dispute that is giving rise to
a demand, then the resolution happens faster as tax payers would then seek a stay of
demand following which the tribunals are at least very prompt in deciding a transfer
pricing dispute.
The way forward
APA mechanism holds promise
The Advance Pricing Agreement holds the promise of a true game changer. This is an
agreement that the tax payer enters with the Advanced Pricing Authority and it broadly
ensures that the transfer prices worked out are not questioned again by the tax
administration.
The 2012 changes in the Dispute Resolution Panel (DRP) rules, that makes it more even
by allowing appeal by the tax department too, hold the promise of faster and more
balanced orders (earlier only the tax payer was allowed to appeal thus making DRP
biased towards the tax department).
Besides, tax payers need to be cautious and maintain a checklist.
As a specific example, the Vodafone issue is likely to be settled with some compromise.
Incidentally, the Finance Minister in his post policy media interactions highlighted that
the offer of conciliation from Vodafone is under Cabinet's consideration.
Advanced Pricing
Arrangement (APA) is
essentially an agreement
that the taxpayer enters
into with the Advanced
Pricing Authority and
that broadly ensures that
the transfer prices
worked out are not
questioned again by the
tax administration.
Advanced Pricing Agreement:
APA is essentially an agreement that the tax payer
enters into with the Advanced Pricing Authority and that broadly ensures that the
transfer prices worked out are not questioned again by the tax administration. APA
has a one-time validity of five years. In usual cases, this would be done on a forward
basis. However, in case a tax payer has an agreement for future transactions, Advanced
Pricing Authority would have a persuasive value over past disputed transactions of
that tax payer too when it is decided by court. Constituents of APA include the Director
General of International Tax and Transfer Pricing, APA team which is headed by a
commissioner who is supported by experts in economics, statistics, law etc and the
Indian competitive authority (Department of Revenue).
Three forms of APA:
Broadly speaking there are three forms of Advanced Pricing
Agreement: i) Unilateral - when the tax payer seeks an understanding and an
agreement with the tax administration of India only, ii) Bilateral - when the tax payer
is seeking an assurance on pricing not just in India but also in the country of the
related party, iii) Multilateral - would mean that there would be similar transactions
with entities outside India but they are located in different jurisdictions. Bilateral
and Multilateral as opposed to Unilateral can be undertaken only if India has a tax
treaty with the concerned country.
AAR is no substitute for APA:
Under the current law, an Advanced Ruling Authority
(AAR) cannot decide on transfer pricing issues. Hence, the very purpose of creating
an APA was to create a parallel body for deciding in advance transfer pricing matters.
Moreover, AAR is a quasi judicial authority with a retired judge of the Supreme Court
6
,,
13 March 2013

Expert Speak
as chairman, while the APA authority is not quasi judicial, it is an administrative
authority. Finally, while APA can be a game changer, the success of an APA program is
not contingent on how many APA applications are received, but how many APA
applications are finalized and an agreement is arrived. Success of APA is not just for
the tax payer but also for the government.
2012 changes in dispute resolution panel law:
Earlier only the tax payer could file an
appeal against the DRP order, while the revenue administration could not. And that
was possibly one of the reasons why the dispute resolution panel at times appear to
be conservative in its decision-making. Despite this, last year in terms of orders that
were passed by the panel, quite a few were in favor of the tax payer. Tax payer's
claims should normally be accepted as appropriate so long as the methodology adopted
by him is fair, is based on available data information and that appears to be fair, given
a set of circumstances. The objective of the dispute resolution panel (DRP), when it
was set up, was to reduce the level of disputes and hence its composition does not
matter. DRP's ruling is time-bound and has to decide within nine months.
Check list for tax payers:
Essentially three - i) be extremely cautious about transfer
pricing legislation, ii) familiarity with growing jurisprudence in India in this arena and
iii) ensure that the documentation is appropriate as that can act as the first defense in
case of disputes.
Transfer pricing and GAAR:
Transfer pricing is nothing but a very specific form of GAAR.
So while GAAR is General Anti-Avoidance, transfer pricing is Specific Anti-Avoidance
which is called SAAR. In the GAAR report it was clarified very clearly that once the
transfer pricing provision is invoked, GAAR will not be invoked.
,,
,,
FY13 Budget changes the
Dispute Resolution Panel
(DRP) rules making it
more even between tax
payers and tax
authorities. Now the
rules allow appeal by
the tax department too,
that holds the promise of
faster and more
balanced orders.
,,
There is growing
realization in the minds
of the government that
the Vodafone issue has
dragged too long and last
year's retrospective
amendment has not
done well to investor
sentiment and
confidence.
,,
Vodafone issue likely to be settled:
The Budget for FY13 introduced some retrospective
changes which had drawn a backlash from industry and foreign investors. Media reports
indicate that there seems to be some compromise which possibly could be reached.
However, at present the law says that indirect transfers are liable to tax since 1961.
We have seen in the media that views have been sought from the Attorney General
on this matter and there is growing realization in the minds of the government that
the Vodafone issue has dragged along too long and last year's retrospective
amendment have not done well to the sentiment of investor confidence. So, the
Vodafone issue is likely to be settled. The 2012 amendment is something that needs
to be repealed and a fresh law introduced if at all the government intends to tax
anything on a retrospective basis. The amendments that were carried out in last
year's budget cannot be implemented given the manner in which the law has been
written. The Vodafone debate is not as much on the retrospective law but has a
bearing on the fact that Vodafone has gone through a full trial in India, right up to the
Supreme Court that has passed a well-reasoned order.
13 March 2013
7

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