Transfer pricing of intellectual property in the automotive industry: A focus on India

The cross-border transfer prices of intangibles, particularly IP, have become a regulatory priority for tax authorities in the host country. They worry that multinationals will set transfer prices that will minimise tax obligations. This has led to increasingly focused transfer pricing regulations and enforcement, making transfer pricing a major tax compliance issue for multinational companies.

This report builds on an earlier piece, Intellectual property in the automotive industry: Transfer pricing aspects, and:

• Focuses on several different multinational business relationships within the Asian automotive industry and
• examines some of transfer pricing models employed to account for the ownership and value of the IP.