Implications of the MAP resolution in India
May 26, 2010
K R Girish and Rohan Phatarphekar of KPMG discuss the reported agreement reached by the Indian and US competent authorities.
The Indian Revenue Authorities have been taking aggressive positions in the area of transfer pricing with margins of captives providing software and busines process outsourcing (BPO) services as the bone of contention. This approach of the revenue authorities has led to several multinational enterprises (MNEs) invoking the mutual agreement procedure (MAP) under the Indo-US double taxation avoidance agreement.
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