News & Media 10th Jun 2026
Our Partner, Rahul Charkha shares his insight in Mint, “MNCs turn to tax treaties to settle cross-border disputes faster.”
He highlights that we are seeing a clear increase in both enquiries and active mandates around the mutual agreement procedure, particularly in matters where a purely domestic remedy does not fully answer the commercial problem. In an anonymous India-Switzerland DTAA case involving an Indian captive service provider, a transfer pricing dispute arose after tax authorities proposed a higher operating margin. MAP discussions focused on transfer pricing methodology, comparable selection corresponding relief from the foreign tax authority.
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