Evolving transfer pricing landscape for GCCs in India
As multinational companies continue to establish 鈥淕lobal Capability Centers鈥� (GCCs) in India, they encounter a complex landscape of transfer pricing challenges. While the cost-plus billing model remains prevalent, recent scrutiny from Indian tax authorities has shifted focus from the traditional debate over arm鈥檚 length mark-ups to the adequacy of the operating expense cost base itself.
This shift has led to significant transfer pricing adjustments, affecting various components such as free-of-cost assets, management fees, pass-through costs, subcontracting expenses, share-based compensation, foreign exchange losses, and adjustments under Indian Accounting Standards (IndAs).
Read a 乐鱼（Leyu）体育官网 article* prepared by 乐鱼（Leyu）体育官网 tax professionals that explores the evolving transfer pricing landscape for GCCs in India.
* Reproduced with permission from Tax Management International Journal, 5/28/2025. Copyright @ 2025 by Bloomberg Industry Group, Inc. (800-372-1033) http://www.bloombergindustry.com