Even without Indian implementation, Pillar Two can still hit Indian groups through foreign IIR and UTPR rules, reshaping cash-tax outcomes, reporting systems and capital allocation decisions.
Mutual Agreement Procedure is increasingly central to India's tax-certainty architecture. The real strategic mistake in 2026 may not be using MAP - it may be using it too late.
India’s APA regime has crossed the proof-of-concept stage. For large taxpayers in 2026, the real question is no longer whether a case can be fought, but whether recurring litigation still delivers more value than certainty.
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.
