CBDT’s Draft Outline Of New Transfer Pricing Regime For Computation of Arm’s Length Price

The CBDT has issued a press release dated 21.05.2015 stating that the Finance (No. 2) Act, 2014 had amended the provision of Income-tax Act relating to transfer pricing regime. The purpose of amendment of section 92C (2) of the Act was to facilitate introduction of “range” concept for determination of Arm’s Length Price of an international transaction or a specified domestic transaction. Further, use of multiple year data for comparability analysis for the purpose of transfer pricing was also to be incorporated. It is pointed out that the said use of multiple year data and “range” concept is proposed to be incorporated through amendments in the Income-tax Rules. For this purpose, the CBDT has prepared a draft outline of the said new regime to be incorporated in the Rules. The CBDT has requested all stakeholders and members of the general public to provide suggestions and comments by 31st May 2015.