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of <h1>Comprehensive Transfer Pricing Rules Enhance Tax Oversight and Prevent Profit Shifting in Multinational Enterprise Transactions</h1> Legal Document Summary:The text analyzes Clause 166 of the Income Tax Bill, 2025, which addresses transfer pricing regulations for international and domestic transactions. The provision empowers tax authorities to scrutinize transactions between associated enterprises, ensuring arm's length pricing. Key innovations include a mechanism for multi-year application of arm's length price determinations, enhanced investigative powers for transfer pricing officers, and procedural safeguards. The clause modernizes existing transfer pricing frameworks by providing greater certainty, reducing litigation, and aligning with international tax standards. The provision aims to prevent tax avoidance while balancing administrative efficiency and taxpayer compliance requirements.
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