India Transfer Pricing Changes Come with Questions, Risks

Tax attorney Alan Granwell was quoted in a Bloomberg Tax article discussing India's proposed three-year block transfer pricing assessments, which aim to streamline audits by consolidating them into a multi-year format. He pointed out that these assessments will only pertain to the Indian tax authority, potentially leading to international complexities if other jurisdictions reassess those same years differently. Mr. Granwell also expressed that although this approach could provide stability within India, it requires more clarity on how it will integrate with international tax laws and practices, as each jurisdiction's regulations might interpret transfer pricing differently.

"This is not some bilateral type of arrangement. You'd have to resolve that under the counterparty's law. So I think how this thing will apply internationally needs to be further fleshed out," he said.

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