RoyaltyStat Blog

Piyush Gupta

Piyush Gupta is a transfer pricing professional with over 15 years of experience at Big 4 and Top 10 accounting firms in the APAC region. He has worked with multinational clients across a range of industries, including hospitality, property development, chemicals, and software; and was also involved in representing multinational clients before the Indian and the Malaysian tax authorities.

From 2013-2015, Piyush also served as the Principal Research Associate for the South Asian countries at the International Bureau of Fiscal Documentation. During this time, he represented IBFD as a subject-matter expert and speaker at international forums and training courses in the APAC and the Africa regions.

His articles have been featured in several publications, including Bizdo, The Journal for International Taxation, India and Asia-Pacific Tax Bulletin.

Piyush is RoyaltyStat’s APAC and Africa Business Development Lead and can be reached at
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Recent Posts

ITAT Transfer Pricing Decision on Use of the Resale Price Method

Posted by Piyush Gupta

The Income Tax Appellate Tribunal (ITAT) of Bangalore, India issued its decision on 04 January 2022, in the case of Randox Laboratories India Private Limited V. The Assistant Commissioner of income tax (IT(TP)A No 2576/Bang/2019) that the Resale Price Method (RPM) is the most appropriate method (MAM) for benchmarking inter-company transaction pertaining to import and resale (without any value addition) of finished goods.

Transfer Pricing Issues in Cloud Computing

Posted by Piyush Gupta

Organizations around the world are gaining valuable insight into not only the potential benefits of the Cloud, but also the practical challenges of adopting these highly disruptive technologies. One of the key considerations when deploying Cloud computing in a multinational enterprise (MNE) is whether or not operating in the Cloud changes the nature of the transaction from a transfer pricing perspective.

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