India Adopts Range Concept and use of Multiple Year Data for Transfer Pricing

On 19 October 2015, India's Central Board of Direct Taxes issued Notification 83/2015, which makes a number of changes concerning the transfer pricing rules under section 92C of the Income Tax Act, 1961. The new rules follow a public consultation launched in May 2015 ({News-2015-05-22/P/3- previous coverage}) on the adoption of the range concept instead of the arithmetic mean concept for determining the arm's length price, as well as the use of multiple year data. The following summarizes the…