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India just collapsed four safe harbor categories into one, cut the margin to 15.5%, and raised the threshold to ₹2,000 crore — which means the annual benchmarking fight that has defined Indian TP compliance for two decades might actually be over for most IT services captives. But "streamlined" is not "free," and the price of certainty includes a margin above arm's length, secondary adjustment obligations, and surrendering your right to MAP. This article explains what changed, what it costs, what still applies, and why India decided now was the moment to stop auditing its way to an answer everyone already knew.
By Josh PostIndia just collapsed four safe harbor categories into one, cut the margin to 15.5%, and raised the threshold to ₹2,000 crore — which means the annual benchmarking fight that has defined Indian TP compliance for two decades might actually be over for most IT services captives. But "streamlined" is not "free," and the price of certainty includes a margin above arm's length, secondary adjustment obligations, and surrendering your right to MAP. This article explains what changed, what it costs, what still applies, and why India decided now was the moment to stop auditing its way to an answer everyone already knew.