Overseas expansion and outbound acquisitions by Indian companies have grown exponentially over the last three years (569 outbound M&A deals worth $47 billion during 2005 to 2007). As business operations expand, multinational enterprises inevitably restructure their global operations to obtain competitive advantage and minimise costs. Indian multinationals are no exception, but there is little guidance from the tax administration, either in the form of judicial or administrative guidelines, in respect of the transfer pricing aspects of business restructurings involving cross-border redeployment of functions, assets and risks between associated enterprises.