Transfer Pricing: Alternate Dispute Resolution Forums
The Transfer Pricing (TP) Alternative Dispute Resolution Forum was held in Chennai on 23rd January 2017. The event brought together a forum of PwC tax partners and directors for sessions, dialogues and panel discussions to discuss TP disputes and various dispute resolution forums to share information/expertise with multinational companies in India. Madhan N, Partner in PwC Chennai’s Tax practice, set the context for the event by discussing the recently concluded strenuous TP assessments and explained the need to be geared up to proactively prepare for putting in place an alternative dispute resolution mechanism.
As the opening session, Jatin Gajjar, Director in PwC Chennai TP practice, gave an insightful and stimulating speech on the theme ‘global tax scenarios.’ He touched on increased transparency across the globe and its effect on the international tax policy environment, how the tax authorities view typical TP issues across the globe and the dispute resolution trends. Sivam and Soumitra, Directors in PwC Chennai TP practice, engaged in a dialogue to discuss the most litigated TP issues across the country. While Sivam dealt with the nuances of parameters involved in a ‘risk based audit system,’ Soumitra explained the intensity of TP adjustments in the future and the resultant pressure on traditional appellate forums to settle TP disputes.
Finally, the event brought together an interesting panel discussion engaging Sriram Seshadri, Partner in PwC Chennai’s litigation practice, Kuntal Sen, Executive Director in PwC Mumbai’s litigation practice and Kunj Vaidya, Partner in PwC Chennai’s TP practice and National Dispute Resolution Lead. A wide of range of TP topics were discussed, such as start-up losses, management service pay-outs, mark-up issues and possibility of deemed international transactions. As a concluding thought, Kun Vaidya shared certain practical insights on selecting the right forum for dispute resolution, considering facts of case. The event brought to together renowned TP professionals and litigation leads to share their experience and insights into the issues impacting businesses across the region.
When sharing their feedback, participants mentioned the event was informative, easy to understand, added value to their work and helped them to network with peers and professionals.