Transfer pricing is back as an agenda item for multinationals as global capability centres (GCCs), technology captives and IT/ITeS arms re-examine long-settled transfer-pricing strategies built around advance pricing agreements (APAs), with the new safe harbour regime set to redraw the contours of tax planning.

At the heart of the issue are three distinct choices facing GCCs and tech captives: whether to remain locked into existing APA margins, how to deal with APA applications that are still under negotiation, and whether to opt for APAs in the future or shift to the safe harbour regime.