When Transfer Pricing Reviews Open Excise Doors: The Hidden Duty Exposure in US-India R&D Arrangements
Transfer pricing audits in India are rarely confined to profit allocation questions — Indian revenue authorities have developed a disciplined practice of using intercompany pricing reviews as a gateway to excise and duty challenges on R&D cost-sharing arrangements, component transfers, and technical service fees. US companies with R&D-intensive Indian operations face a compounded audit risk that their legal and tax teams often manage in separate silos, leaving the intersection of transfer pricin