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CBDT Issues Comprehensive Transfer Pricing Safe Harbour Rules for FY 2026-27
New safe harbour provisions expand coverage to include software development, clinical trials, and EV component manufacturing, offering certainty to multinational enterprises.
The Central Board of Direct Taxes (CBDT) has notified comprehensive Transfer Pricing Safe Harbour Rules for Financial Year 2026-27, significantly expanding the scope of covered transactions and revising the operating profit margin thresholds.
The new rules address a longstanding demand from multinational enterprises (MNEs) operating in India for greater tax certainty. Safe harbour rules allow taxpayers to adopt pre-determined margins for specified categories of international transactions, reducing the risk of transfer pricing adjustments and litigation.
Expanded coverage
For the first time, the safe harbour framework now covers software development services (operating margin of 17-20%), clinical trial management (18-22%), and electric vehicle component manufacturing (12-15%).
Revised thresholds
The operating profit margins for existing categories have been recalibrated based on contemporaneous data. IT-enabled services margins have been revised from 18-22% to 16-20%, reflecting current market conditions and global benchmarking studies.
Impact assessment
Tax analysts estimate that the expanded safe harbour rules could reduce transfer pricing disputes by approximately 35% and save MNEs an aggregate ₹2,500 crore in compliance and litigation costs annually.
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