Income-tax (16th Amendment), Rules, 2013. - 73/2013 - Income Tax

Safe harbour rules permit specified transfer pricing margins and rates to be accepted for qualifying cross-border transactions.

The rules introduce Safe Harbour provisions under section 92CB, defining eligible assessees and eligible international transactions (services, intra-group loans, corporate guarantees, contract R&D, and auto component exports), prescribing objective transfer pricing parameters (minimum operating profit margins, interest rate margins, and guarantee fees) that, if met and validly opted into via Form 3CEFA, will be accepted by tax authorities for the initial and four subsequent assessment years subject to procedural verification, exclusions for certain jurisdictions, and preservation of other documentation obligations.