Ep. 125: India's evolving transfer pricing landscape

July 21, 2026

Kristina Novak and John Cianfrone are joined by Eric Mehta, a Partner in PwC India’s Transfer Pricing practice. Kristina, John, and Eric discuss India’s 2026 Union Budget transfer pricing reforms, including significant changes to the safe harbor regime and enhancements to the Advance Pricing Agreement (APA) program. They explore the policy objectives behind the reforms, how the changes are intended to increase tax certainty and reduce controversy, the expansion and simplification of safe harbor eligibility, recent improvements to the APA process, and key considerations for multinational businesses evaluating transfer pricing policies and planning opportunities in India.





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Ian Dykes

Ian Dykes

Global Transfer Pricing Network Leader, PwC United Kingdom

Tel: +44 7803 149718

Kristina Novak

Kristina Novak

Washington National Tax Services, Transfer Pricing, Principal, PwC US

Tel: +1 (469) 878-4552

John Cianfrone

John Cianfrone

Washington National Tax Services, Transfer Pricing, Director, PwC US

Tel: +1 (646) 951-7680

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