New Safe Harbour Rules for Intra-Group Loans and Guarantees: How Safe Is the New Harbour?

Journal
Bilaney, S.K.
India
Finance and Capital Markets (formerly Derivatives & Financial Instruments) 2017 (Volume 19), No. 6
PriceUSD 45

The Indian government has recently amended the safe harbour rules relating to intra-group loans and guarantees. The analysis of these rules clearly indicates the intent of the Indian government to reduce transfer pricing litigation and provide certainty to taxpayers regarding their transfer pricing positions.