Safe harbour transfer pricing rules set prescribed margins, interest benchmarks, and fee thresholds for eligible international transactions. Safe harbour is provided for eligible international transactions where the declared transfer price is accepted if the assessee's option is valid and the prescribed conditions are met. The covered transactions include information technology services, intra-group loans in Indian rupees and foreign currency, corporate guarantees, contract research and development services for generic pharmaceutical drugs, manufacture and export of core and noncore auto components, low value-adding intra-group services, and data centre services. The rule also specifies reference rates, credit-rating treatment, a three-tax-year block period from tax year 2026-2027, and provides that no comparability adjustment or allowance under section 165(3)(a)(ii) applies to accepted prices.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Safe harbour transfer pricing rules set prescribed margins, interest benchmarks, and fee thresholds for eligible international transactions.
Safe harbour is provided for eligible international transactions where the declared transfer price is accepted if the assessee's option is valid and the prescribed conditions are met. The covered transactions include information technology services, intra-group loans in Indian rupees and foreign currency, corporate guarantees, contract research and development services for generic pharmaceutical drugs, manufacture and export of core and noncore auto components, low value-adding intra-group services, and data centre services. The rule also specifies reference rates, credit-rating treatment, a three-tax-year block period from tax year 2026-2027, and provides that no comparability adjustment or allowance under section 165(3)(a)(ii) applies to accepted prices.
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