Intra-group services: India’s benefit-test obsession is becoming a tax-certainty problem
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
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
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?
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.
SaaS Tax and India’s Cross-Border Misfit: Royalty, FTS, Business Profits—or a Broken Taxonomy?
Cross-border SaaS tax in India still relies on old labels—royalty, FTS, and business profits. That mismatch is now raising withholding risk, pricing uncertainty, and treaty disputes.