Rahul has over 25 years of experience in handling taxation & regulatory matters in India. He specializes in transfer pricing, particularly inbound & outbound planning assignments; supply chain management projects; profit attribution to permanent establishments, etc.
Rahul has been a tax partner in PwC and KPMG for an aggregate period of 19years, including having served both the organisations as their national transfer pricing leaders.
Rahul independently handles litigation for top companies at the level of Tax Tribunals & Authority for Advance Ruling.
Rahul has won several landmark rulings before Tax Tribunals in the field of transfer pricing, creating precedents, both nationally and globally, in matters relating to Berry Ratio, Marketing Intangibles; Selection of Tested Party; Corporate Guarantee; Profit Split Method; Supply Chain nuances etc.
Rahul has handled several APAs 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; profit split models for royalties; etc.
Rahul was the country reporter on the topic, "Non Discrimination in international tax matters", for the IFA Congress held in Brussels in 2008.
Rahul was invited by the OECD to speak in the 2012 Paris roundtable conference on developing countries' perspective on APAs.
Rahul was invited by the Indian Revenue Board in 2015 to impart training to transfer pricing Directors & Commissioners of the Indian Revenue, on the topic of marketing intangibles.
Rahul was invited by the President of the Tax Tribunal in 2012 to impart training to Members of the Tribunal on the topic of transfer pricing.
Rahul has been consistently rated as amongst the leading transfer pricing professionals; and also tax litigators in India by Euromoney and International TaxReview, since 2010.
Some of the major wins of Rahul before the Tax Tribunals in transfer pricing matters are in the following cases, setting precedents, both in India and globally:
- BMW India - marketing intangibles in the case of distributors, distinguishing negative ruling of Special Bench of Tribunal in the case of LG Electronics;
- GAPIndia - remuneration model for procurement services company,addressing issues of "Berry Ratio" & "location savings";
- Global One India - accepting "residual profit split method" & distinguishing it from "comparable profit split method", being covered by Income Tax Rules; also holding "sixth method" to have retrospective operation;
- Development Consultants - concept of "tested party", as least complex of two transacting entities approved; foreign related party (distributor) accepted as "tested party" in case of tax payer, being Indian headquartered entrepreneur;
- Landis + Gyr - foreign related parties (suppliers of raw materials) accepted as" tested parties" In case of tax payer, being entrepreneurial licensed manufacturer.
- Ranbaxy Pharmaceuticals - foreign related parties (distributors) accepted as "tested parties" in case of Indian headquartered entrepreneur; applied APA for future years to solve past disputes without roll back.
- Tega Industries - concept of shareholder's function in the context of financial guarantee extended for overseas SPV, relating to acquisition of step-down target companies;
- ITC Infotech - business models for agency and distribution of services;
- Schefenacker Motherson - concept of "cash profit" to sales as profit level indicator;
- Cheil Communications - concept of "pass through cost" for intermediary company;
- Fulford India - concept of "value added distributor" for secondary manufacturers in pharmaceutical sector.