Managing International Business Disputes in New Transfer Pricing Regime : The Effectiveness Rests with Skilled Human Resources

Transfer pricing rules in India, were introduced in 2001, however, there are issues of tedious documentation, complicated procedures, rigorous penalties. Therefore, this subject has emerged as biggest source of courtroom battles. Recently, system has been improved by incorporating APAs, SHRs, Roll Back, Range Concept, etc. The success of this new transfer regime, however, rests with the availability and capability of human resources. In this scenario this paper discusses the relevant concepts and emphasise upon the need to fill up the gap between demand and supply of human resources so as to make the system more effective and faster