TFD Policy Research Desk

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TFD Policy Research Desk delivers sharp, insightful analysis of India’s evolving fiscal and regulatory landscape. It decodes tax reforms, developments, government policies, and global fiscal trends, offering professionals clear, timely perspectives that bridge complex legislation with real-world business and compliance implications.

Exclusive articles:

Transfer Pricing True-Ups at Year-End: Commercial Hygiene or Audit Trigger by Design?

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Transfer pricing true-ups are not inherently suspect. But in India, a year-end margin correction becomes defensible only when contracts, monitoring, settlement and Rule 10D evidence all point to one coherent pricing policy.

Intra-group services: India’s benefit-test obsession is becoming a tax-certainty problem

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India's transfer pricing fights over intra-group services have become too fixated on proving 'benefit' after the fact. A better test would ask what service was actually rendered, why it was needed, and whether it was priced credibly.

When AMP Spend Does – And Does Not – Look Like a Marketing Intangible Issue

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Local marketing spend in India often sits inside routine distribution economics. The harder question is whether the taxpayer can prove who controlled that spend, who bore the risk, and who kept the commercial upside.

DEMPE Analysis Is Turning Formulaic—and That’s Becoming a Transfer Pricing Risk

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DEMPE analysis is becoming harder to fake. As transfer pricing audits mature and routine disputes get simplified, template-heavy intangible files are increasingly exposed as evidence-light and adjustment-prone.

MFN clause after Nestlé: treaty shield or drafting illusion?

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MFN clause disputes in India are no longer a technical footnote. Recent rulings, a 2025 tribunal order, Switzerland’s reset and France’s 2026 rewrite show why treaty parity now turns on wording, timing and notification discipline.
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Breaking

Auditor Independence Gets a Cooling-Off Clause: MCA’s Cross-Selling Squeeze on the Big Four

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MCA’s proposed auditor independence reform would extend non-audit service restrictions for three years after audit tenure ends, targeting the cross-selling economics that have long strengthened large multidisciplinary networks.

Audit Quality Maturity Model and the Big Four Question Returns

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ICAI has widened the mandatory reach of the Audit Quality Maturity Model to group audits and other public-interest engagements. The move sharpens India's audit-quality architecture, but it also reopens the harder question of whether domestic firms can build credible scale against the Big Four.

NFRA inspection reports put Big Four-linked audit networks on notice

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NFRA’s March 2026 inspection reports have turned audit quality into the central governance story around India’s Big Four-linked audit networks, with independence, group controls and evidence quality all under pressure.

IBC Amendment Act 2026 Moves Insolvency Out of the Waiting Room

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The IBC Amendment Act 2026 is India’s clearest attempt yet to cut insolvency delays where they actually begin—at admission, in liquidation and in the messy afterlife of resolution-plan implementation.