• Prof. (Dr.) Pawan Kumar Chugan Institute of Management, NIrma University, Ahmedabad
  • Prof. (Dr.) Nilam Panchal DPPG, B. K. School of Professional and Management Studies, Gujarat University, Ahmedabad



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


It is now very widely known that supply of good and services across the borders by the associated / related companies is subject to the high risk of having disputes with the taxation authorities for abuse of transfer pricing for their international operations which very often may result in litigations. Thus, managing the supply chain when it is related with transfer pricing is extremely important for the smooth conduct of business, This paper in this context, therefore, first explains the relevant concepts of supply chain operations between the associated companies with tax implications, transfer pricing, abuse of transfer pricing, Arm’s Length Pricing, Advance Pricing Agreement, Safe Harbour Rules and then explains how such risk of disputes and litigations may be minimized or even eliminated by adopting a suitable legitimate techniques as per the prescribed guidelines and laws of the national and international institutions enabling MNEs to supply tangible and intangibles to their associate companies without having any issues with 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 (1999). “International Technology Transfer”, Mumbai, Himalaya Publishing House.

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.

Chugan, Pawan Kumar (2014). Transfer Pricing and MNCs: Safe Harbour Rules (SHR) and Advance Pricing Arrangement (APA) to Facilitate FDI and Reduce Litigation in India. In “Emerging Paradigms in Corporate Finance and Regulatory Framework, Eds. Prag Rijwani and Neeraj Amarnani, ISBN: 978-81-923049-3-9, Print Quick, Institute of Management, Nirma University, Ahmedabad, Jan. , pp. 355-367. accessed on Jan. 20, 2024.

Chugan Pawan K and Panchal Nilam (2022). Managing Global Supply Chain: Transfer Pricing Issues and Solutions. International Journal of Management, Public Policy and Research, E-ISSN: 2583-3014, B. K. School of Professional & Management Studies, Gujarat University, pp.34 – 41. SSRN:

Cogent (2023). Safe Harbour Rules. accessed on Jan. 08, 2024.

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”, New Delhi, Ashish Publishing House, 1986.

Favourate Sebele-Mpofu, Eukeria Mahiri and Samantha Chantelle Schwartz (2021). An exposition of transfer pricing motives, strategies and their implementation in tax avoidance by MNEs in developing countries. Cogent Business and Management. Vol. 8, Issue 1. accessed on Jan. 16, 2023.

Jain Arinjay (2021). Arm’s Length Transfer Pricing. June 4, accessed on 16 Jan. 2023.

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.

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

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

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

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

Mint (2019). Transfer Pricing: Advance Pricing Pact vs Safe Harbour Provision. accessed on Jan. 08, 2024.

MOF (2023). CBDT Signs 95 Advance Pricing Agreements in FY 2022-23, Ministry of Finance, Govt. of India. PIB, 31 March. Accessed on Jan. 4, 2024.

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 Feb. 7, 2021). Details also available on accessed on Jan. 17, 2022.

Peter, Roost (2006). “How Multinational Corporations Avoid Paying Taxes”, Scoop Independent News, November 22.

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.

Soan, A. (2014). Advance Pricing Agreements. Asia Pacific Bulletin. Retrieved from IBFD: 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?. price/ Accessed on Jan. 13, 2022.

Vaitsos, C.V. (1974). “Inter – Country Income Distribution and Transnational Enterprises”, Oxford, Oxford University Press.

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




How to Cite

Chugan, P., & Panchal, N. (2024). MANAGING SUPPLY CHAIN IN CONTEXT OF TRANSFER PRICING. International Journal of Management, Public Policy and Research, 3(3), 1–7.




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