Executive summary
India’s Central Board of Direct Taxes (CBDT), the apex Indian tax administration body, first issued transfer pricing (TP) safe harbor rules (SHR) in 2013. The SHR listed specific transactions that were covered, provided procedures for adopting safe harbors, the transfer prices to be adopted, the compliance procedures upon adoption of a safe harbor and circumstances in which a safe harbor adopted may be held to be invalid. Those rules were applicable for five years and ended with…