Praneeth Narahari

After decades of litigation-driven uncertainty, India has finally proposed a clear, statute-based framework that offers a methodology for attributing profits to the operations conducted by the foreign companies in India. National Institution for Transforming India Aayog, Tax Policy Working Paper Series-I, Enhancing Certainty, Transparency, and Uniformity in Permanent Establishment and Profit Attribution for Foreign Investors in India (Oct. 2025).

It’s fascinating to see how the global minimum tax rule of the OECD/G20’s Pillar Two initiative is steadily reshaping tax narratives across the world—even in countries long known for low or no corporate taxes. The reform’s policy design integrates individual jurisdictions’ economic interests with international alignment. As multinational enterprises respond to Pillar Two’s implementation, transfer pricing will increasingly become a critical tool in navigating its planning and compliance landscape.