- Honours Graduate in Commerce
- Chartered Accountant
Areas of specialization
- Transfer Pricing
- Supply Chain Planning
- Permanent Establishments
- International Taxation and BEPS
Rahul MitraSenior Advisor
Rahul Mitra has over 27 years of experience in handling transfer pricing, supply chain management projects, international taxation, BEPS, profit attribution to permanent establishments, etc.
Rahul was a tax partner with PwC and KPMG in India for an aggregate period of almost 20 years, including having served both the organisations as the leader of their national transfer pricing practices.
Rahul was country reporter on the topic, “Non-Discrimination in international tax matters”, for IFA Congress held in Brussels in
2008. Rahul was invited by OECD to speak in 2012 Paris roundtable conference on APAs.
Rahul was invited by the Tax Tribunal in 2012; and the Indian Revenue Board in 2015 and 2019 to impart training on the topic of transfer pricing to Members of the Tax Tribunal and Senior Officials of the Indian Revenue respectively. Rahul has been rated as a leading transfer pricing professional and tax litigator in India by Euromoney and International Tax Review, since 2010.
Rahul received the “International Tax Contributing Author of the Year” award in the subject of transfer pricing in 2019 from Bloomberg Tax. Rahul is a member of global editorial board of the international web-based tax magazine, Bloomberg Tax Transfer Pricing Forum.
Rahul has authored a book on transfer pricing, styled as Decoding Transfer Pricing for Selling Functions”.
Rahul independently handles litigation for top companies before Tax Tribunals; and has won several landmark rulings creating precedents in India, in matters relating to Berry Ratio, Marketing Intangibles; Selection of Tested Party; Corporate Guarantee; Profit Split Method; etc.
Rahul has handled several APAs and MAPs in India, involving clients from across industries, covering complex transactions, e.g. industrial franchise fees under non- integrated principal structures; contract R&D service provider model; distribution models with related marketing intangible issues; financial transactions (loans and guarantees); profit split model for royalties; etc.