• Dr. Pawan Kumar Chugan PDEU
  • Dr. Nilam Panchal B.K. School of Professional and Management Studies



Global supply chain management, Transfer Pricing, Abuse of transfer Pricing, Arm’s length pricing (ALP), Abuse of Transfer Pricing, Advance Pricing Agreement (APA), Safe Harbour Rules (SHRs), Mutual Agreement Procedure (MAP)


World trade of goods and services is based upon the global supply chain and logistics management, and its flow is determined by the drivers of supply chain management. For a company to be successful in the new millennium where a paradigm shift has taken place it becomes necessary that its supply chain strategy gets fit with its competitive strategy so as to strike an appropriate balance between the supply chain’s efficiency and responsiveness. One of the supply chain management’s  drivers, to achieve this fit is known as “Pricing”. In the context of global supply chain management, Transfer Pricing, with its components such as Arm’s Length Pricing (ALP), Advance Pricing Agreement (APA), Safe Harbour Rules (SHRs), etc. play a very important role and, therefore, in this paper an attempt has been made to explain issues relating to transfer pricing vis-à-vis solution for the same, so that MNEs may operate and supply their tangibles and intangibles to their related companies globally without having any disputes / litigations with a the taxation authorities.


Chandrashekhar, C. P. and P. Purkayastha (1982). Transfer Pricing in Indian Drug Industry: An Estimates and its Implications. Social Scientist. Jan., pp. 3-10.

Chugan Pawan Kumar (1993). The Impact of Foreign Collaboration (Technology) on India’s Foreign Trade and Industrial Competitiveness: A Study of Automobile Ancillary Industry. Ph. D. Thesis, Jamia Millia Islmia, New Delhi.

Chugan, Pawan Kumar (1999). International Technology Transfer. Mumbai, Himalaya Publishing House.

Chugan, Pawan Kumar (2007). International Transfer Pricing, Taxation and Need for Advance Pricing Arrangement. Pravartak, Volume II, Issue 2, Jan.– March, p.p.134 -140.

Chugan Pawan Kumar (2007a). Advance Pricing Arrangement, Transfer Pricing and MNCs: The Implications for Foreign Investment in India, in (Ed) Delener Nejdet, Leonora Fuxman, Luis Eduardo Rivera Solis and Che-Jen Su, pp. 382-392.

Chugan Pawan Kumar (2008). International Transfer Pricing in Services MNCs: A Case of Banking and Insurance Sector. in (Ed.) Dhar Upinder, Nath, V.V., Nair Satish K. and Yadav Prabhat Kumar, p.p. 225-238.

Chugan Pawan Kumar (2010). International Transfer Pricing in India: The New Era of Advance Pricing Arrangements to Benefit both MNCs and Taxation Authority, in Mehta Shantanu, and Neeraj Amarnani, pp. 505-522.

Delener Nejdet, Leonora Fuxman, Luis Eduardo Rivera Solis and Che-Jen Su (2007). Achieving Competitive Advantage Through Managing Global Resources, (Ed.), Global Business and Technology Association, State University of New York at Old Westbury, New York.

Deloitte (2012). Advance Pricing Agreement _ Frequently Asked Questions. accessed on Jan. 16, 2022.

Deo, Som (1975). Multinational Corporations and the Developing Countries. Economic Affairs, August, Vol. 20, No. 8.

Deo, Som (1977). Modus Operandi of Drug Multinationals. Economic Affairs, April, Vol. 22, No. 4.

Deo, Som (1986). Multinational Corporations and Third World, Ashish Publishing House, New Delhi.

Dhar Upinder, Nath, V.V., Nair Satish K. and Yadav Prabhat Kumar (2008). New Age Marketing: Emerging Realities, Excel Books, New Delhi.

Krishna, Sridhar (1984). A Note on Transfer Pricing – Some Theoretical Issues and Empirical Evidences, Social Scientist 12, pp. 22-32.

Kumar, Nagesh (1984). Social Cost Benefit Analysis of an Export Oriented Project with Foreign Collaboration, Industry and Development, No. 10, UNIDO.

Kumar, Nagesh (1985). Cost of Technology Imports: The Indian Experience. Technology and Development Studies. National Institute of Science, New Delhi. April. Also appeared in Economic and Political Weekly, August 21, pp. M.103-114.

Lall, Sanjaya (1973). Transfer Pricing by Multinational Manufacturing Firms. Oxford Bulletin of Economics and Statistics, Vol. 35, pp. 173-95.

Lall, Sanjaya (1979). Transfer-Pricing and Developing Countries: Some Problems of Investigation. World Development, Vol. 7, pp. 59-71.

Lexology (2019). Transfer Pricing in USA. Jan. 7, accessed on Jan. 16, 2022.

Mann, T. S. (1982). Transfer of Technology. Himalaya Publishing House, Bombay.

Mehta Shantanu, and Neeraj Amarnani (2010). Sustaining Shareholder Value: Role of Investors and Regulations, Eds. Excel Books, New Delhi.

Ludwig Christophe (2020). How to Deal With the Impact of Covid -19 on Transfer Pricing. accessed on Jan. 15, 2022.

Martin Julie (2019). Cross-border Tax Disputes continued to rise in 2019, new OECD Stats Say. accessed on Jan. 13, 2022.

Mishra, S. (2019, July 26). Transfer Pricing in India. tax/transfer-pricing-india.html accessed on 8 Jan., 2022.

OECD (2006). Glossary of Statistical Terms: Arm’s Length Principle. Annual Report on the OECD Guidelines for Multinational Enterprises: Conducting Business in Weak Governance Zones. Paris. Accessed on Jan. 13, 2022.

OECD. (2017). ,Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration. Retrieved from OECD: transfer-pricing-guidelines-for-multinational-enterprises-and-tax-administrations- 20769717.htm (accessed on February 7, 2021). Details also available on accessed on Jan. 17, 2022.

PWC (2011). Certainty in the Uncertain World of Transfer Pricing: White Paper on APA in India.

Peter Rost (2006). How Multinational Corporations Avoid Paying Taxes, For details, see Scoop Independent News, November.

Ramanujam, T.C.A (2001). How to Make Transfer Price Effective.

REGTPG (2002). Report of Expert Group on Transfer Pricing Guidelines, submitted to the Government of Indian, Ministry of Finance and Company Affairs, August.

Sharma, S. (2014). Safe Harbour Rules-Transfer Pricing. accessed on Feb. 5, 2021.

Shira, D. (2018). Transfer Pricing in India Explained. https://www.india- accessed on 7 February, 2022.

Sikarwar Deepshikha (2012). Rules for Advance Pricing Coming Soon. The Economic Times, August 14, p.11.

Soan, A. (2014). Advance Pricing Agreements. Asia Pacific Bulletin. Retrieved from IBFD: Bulletin/collections/aptb/html/aptb_2014_01_in_1.html accessed on February 7, 2021

Subrahmanian, K. K. and P. Mohan, Pillai (1976). Implications of Technology Transfer in Export-led Growth Strategy. Economic and Political Weekly, Oct. 30, pp. 1729-35.

Taxman (2021). What is Arm’s Length Price?. Accessed on Jan. 13, 2022.

UN (1965). Tax Treaties between Developed and Developing Countries. New York, U. N. Document ST/ESA/18, Fifth Report.

Vaitsos, C.V. (1983). Inter – Country Income Distribution and Transnational Enterprises. Oxford University Press.

Venu, S. (1983). Transfer Pricing by Multinational Corporations”, Bombay, Commerce Publications Ltd.




How to Cite

Chugan, P., & Panchal, N. (2022). MANAGING GLOBAL SUPPLY CHAIN: TRANSFER PRICING ISSUES AND SOLUTIONS. International Journal of Management, Public Policy and Research, 1(2), 34–41.