Updates on Safe Harbour
Information Technology (IT) companies today operate in an environment of heightened transfer pricing scrutiny, with audits becoming increasingly frequent and resource‑intensive. These audits often have cascading implications across subsequent years, resulting in a significant drain on management bandwidth, time, and costs—prompting many organizations to proactively account for them in their planning cycles.
Against this backdrop, the CBDT’s notification of the Income‑tax Rules, 2026, issued on 20 March 2026, represents a noteworthy evolution of the #Safe Harbour (SH) framework, introducing targeted refinements with a clear emphasis on the IT/ITeS sector, including:
Rationalisation through consolidation of multiple service categories into a unified IT services classification- IT/ ITes/BPO/KPO/ Contract R&D wholly or partially relating to software development services all clubbed under IT Services
A calibrated reduction in the Safe Harbour margin to 15.5%
In this evolving landscape, Safe Harbour emerges as a compelling strategic alternative, offering enhanced certainty and reduced litigation exposure.
VSTN’s flyer seeks to provide clear, actionable insights to help #eligible IT services companies assess the viability and strategic merits of opting for the Safe Harbour regime.
About us
VSTN Consultancy is a Global Transfer Pricing firm with extensive expertise in the field of international taxation and transfer pricing. VSTN Consultancy has been awarded by International Tax Review (ITR) as Best Newcomer in Asia Pacific – 2024 and is ranked as one of the recommended transfer pricing firms. VSTN has also been nominated in 9 Categories under APAC, EMEA and Middle East Region ITR awards 2025. VSTN has its offices in India and Dubai.
Nithya Srinivasan, Founder of VSTN Consultancy, was named Middle East Transfer Pricing Practice Leader of the Year, recognizing her outstanding leadership and contribution to the profession. VSTN also received the Best Newcomer in the Middle East award from International Tax Review, showcasing its rapid growth and excellence in global transfer pricing advisory.
VSTN Consultancy has been honored with the Best Global Transfer Pricing Consultancy 2025 – India award at the prestigious Wealth & Finance Management Consulting Awards 2025.
Our offering spans the end-to-end Transfer Pricing value chain, including design of intercompany policy and drafting of Interco agreement, ensuring effective implementation of the Transfer Pricing policy, year-end documentation and certification, BEPS related compliances (including advisory, Masterfile, Country by Country report), safe harbour filing, audit defense before all forums and dispute prevention mechanisms such as Advance Pricing agreement. VSTNs senior partners have been ranked in ITR in the list of recognized Practitioners.
Locations Served
| Australia | Philippines |
| Belgium | Singapore |
| Denmark | Switzerland |
| India | Turkey |
| Italy | UAE |
| KSA | UK |
| Mexico | USA |
| Netherlands | Zambia |
Core Team
vstn
Nithya Srinivasan
Srilakshmi Hariharan
S Ranjani
E Rajesh
Nitya Joseph
Saranya Nagarajan
Triveni Palla
9:19:52/02:24.4
centest@vetmconsultancy.com
www.vstnconsultancy.com
Our Licensed Databases
| SNo | Database | Provider |
|---|---|---|
| 1 | TP Catalyst | Moody’s |
| 2 | ORBIS | Moody’s |
| 3 | Loan Module | Moody’s |
| 4 | IP & Royalty Data | Moody’s |
| 5 | Royalty Rates and Benchmark Module | ktMINE |
| 6 | Services CUT | ktMINE |
| 7 | EDF-X Bond Database | Moody’s |
| 8 | EDF-X Credit Risk Analytics | Moody’s |
| 9 | Loan Module | Royalty Range |
| 10 | Transfer Pricing Documenter (formerly Thomson Reuters Onesource) | Ryan |
| 11 | Prowess | CMIE |
As businesses expand across borders, navigating complex transfer pricing regulations becomes critical. At VSTN Consultancy, a global transfer pricing firm, we specialize in helping companies stay compliant and competitive across key markets including:
India | UAE | Singapore | USA | KSA | Dubai | Asia Pacific | Europe | Africa | North America
Whether you’re preparing for benchmarking intercompany transactions, or developing robust TP documentation, our team is here to support your international strategy and Compliance.
Contact us today to explore how we can partner with you to optimize your global transfer pricing approach.
#TransferPricing #TransferPricingFirm#VSTNConsultancy #TaxCompliance #IndiaUAEUSA
#TPExperts#TransferPricingExperts#GlobalTransferPricingFirm