Commercial transactions between the different parts of the multinational groups may not be subject to the same market forces shaping relations between the two independent firms. “Transfer Price" may be arbitrary and dictated, with no relation to cost and added value, diverge from the market forces

Multinational organizations are operating in an environment of unprecedented complexity.

"The rising volume and variety of intercompany transactions and transfer pricing regulations, accompanied by increased enforcement activities worldwide have made transfer pricing a leading risk management issue for global businesses. The Indian Transfer Pricing Code prescribes that income arising from international transactions or specified domestic transactions between associated enterprises should be computed having regard to the arm’s-length price."

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