An integrated approach to formulating a transfer pricing strategy concerning marketing and distribution affiliates

This article presents a comprehensive analysis of the possible and proper transfer pricing policy for multinational enterprises operating in India through either a trader/distributor, limited distributor or an agent/service provider. Transfer pricing regulations have been implemented in India for three years now, and the author makes clear that taxpayers who have not performed the necessary analyses and maintained adequate documentation, run the risk of being audited and becoming subjected to income reassessments.