Analyzing from a Comparability Perspective,
the Mark-ups Observed in India

TPED / Research Areas  / Coping with the lack of comparables  / Analyzing from a Comparability Perspective,the Mark-ups Observed in India

TPED partners with to launch a research project looking at “Analyzing from a Comparability Perspective, the Mark-ups Observed in India”. is a one stop destination that equips tax practitioners on a real-time basis with updates and analysis of all income tax rulings and news both domestic and international.

This project is part of the wider TPED’s Comparability Research Project initiated in 2018.

There is global attention on the high markups seen in India Competent Authority and court cases on offshore services (R&D, IT, knowledge management, possible fees for technical services, etc). India as the leading global offshoring, BPO hub and center is key to consensus and consistency in global TP policies for Multinational Enterprises and Competent Authority negotiations to avoid double taxation. A further significance is that India is increasingly seen as a reference point for developing countries from Kenya to Indonesia who refer to Indian cases as being more comparable to their circumstances.

The aim of the project is to analyse the relatively high mark-ups observed in India using Indian databases to examine the extent to which these can be explained or accounted for by conventional OECD comparability analysis and whether these can be reconciled with the levels of mark-ups observed elsewhere in the world using OECD comparability adjustment techniques. The results of this study may be very insightful for developing countries and may inform on the current exploration by the United Nations and Africa countries as to creating safe-harbours that makes sense from technical and ease of tax administration perspectives.

The project involves the following TPED members: Sam, Emily, Robert-Jan and Sébastien.