India’s Revised Safe Harbor Rules: A Strategic Opportunity for U.S. Multinationals With Indian Operations |

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India’s 2025 Income-tax Act, effective April 1, 2026, introduces a revised statutory framework for Safe Harbor rules, implemented through the Income-tax Rules 2026. These changes aim to simplify transfer pricing compliance, reduce litigation, and provide greater certainty for multinational enterprises operating in India, particularly those with Global Capability Centers (GCCs), data centers, and supply chain operations.

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Authors

Kevin Kiyan

Lucia Fedina

Andrea Adler

David Talakoub