India – MAP with Japan; manufacturer’s transfer pricing resolved

July 17: A large manufacturing company has resolved its transfer pricing issues by means of a mutual agreement procedure (MAP) reached between India and Japan.

The MAP was signed in less than a year of its application, following two meetings between the Competent Authorities of India and Japan.

The MAP process reflects India’s commitment to enter into dialogue with the tax authorities of other countries (parties to India’s tax treaty network), and shows that the MAP process may be an effective means of resolving disputes relating to transfer pricing.