Understanding Recent Tribunal Rulings on Transfer Pricing: Key Developments for Global Tax Compliance in 2025
As multinational enterprises continue to navigate an increasingly complex regulatory landscape, staying abreast of key transfer pricing (TP) developments is critical. The January 2025 edition of CNK & Associates LLP’s Quarterly Insights provides expert analysis on recent Indian tribunal rulings with significant implications for cross-border transactions, permanent establishments (PEs), and arm’s length pricing (ALP) assessments.
This update covers pivotal judgments where tribunals ruled on interest adjustments for debt-free companies, rejected the “mirror ALP” defense in foreign-company assessments, and classified Indian PEs as separate enterprises for TP purposes. These decisions reinforce the importance of robust documentation, appropriate benchmarking, and compliance with Indian TP laws.
Key highlights include:
- Tribunal relief for debt-free entities on imputed interest for outstanding receivables.
- Validation of CUP method and rejection of base erosion claims in transactions with AEs.
- Clarification that Indian PEs must be treated as separate entities for ALP benchmarking.
This digest not only informs but also empowers taxpayers to navigate their filings with clarity and confidence.
