3 Significant Transfer Pricing Moments of 2016


While the year 2016 witnessed some landmark events like BREXIT, Donald Trump Presidency in the US, European Commission’s verdict in the Apple state-aid case and the release of Multilateral Instrument text, Indian transfer pricing arena also had its share of the limelight. India implemented BEPS recommendation on Country-by country reporting (CbCR) through Budget 2016. More than 1000 transfer pricing judgments were delivered by the Tribunals and Courts while CBDT surpassed itself by signing 53 APAs including 4 bilateral and 49 unilateral APAs in 2016. Further, 66 MAP cases relating to TP issues were agreed to be resolved during the year, and one of the most controversial issues of India’s transfer pricing litigation i.e. marketing intangibles, has now reached the Apex Court.