Rahul Mitra

Partner and Head, Transfer Pricing and BEPS

KPMG in India

As the head of Transfer Pricing and BEPS at KPMG in India, Rahul brings over 23 years of experience in handling taxation and regulatory matters in India to the fore. He specialises in transfer pricing - particularly with respect to inbound and outbound planning assignments, advising on profit/cash repatriation planning, value chain transformation or supply chain management projects, and profit attribution to permanent establishments, etc.

Rahul has an independent grip on litigation for leading companies at the level of Tax Tribunals and Authority for Advance Ruling (AAR). At least 50 of the cases independently argued by him in direct tax and transfer pricing matters have been reported in leading tax journals in India.

In his personal capacity, Rahul has handled several Advance Pricing Agreements (APAs) in India, involving clients from across industries, covering complex transactions, for instance industrial franchise fees under non-integrated principal structures, contract research and development (R&D) service provider models, distribution models with related marketing intangible issues, financial transactions, profit split models for royalties, etc.

Rahul has been consistently rated as amongst the leading transfer pricing professionals and tax litigators in India by Euromoney and International Tax Review (ITR), since 2010. On the global stage, Rahul was the country reporter on the topic, ‘Non Discrimination in international tax matters’, for the International Fiscal Association Congress held in Brussels in 2008. He was also invited by the Organisation for Economic Co-operation and Development (OECD) to speak in the 2012 Paris roundtable conference on developing countries’ perspective on APAs.

He has also been recognised as a leading Tax Controversy Leader in India and has been featured in the ITR’s Tax Controversy Leaders Guide, 2015. In addition, he was invited by the Indian Revenue Board in October, 2015, to impart training to the transfer pricing directors and commissioners of the Indian Revenue, on the topic of marketing intangibles.


Areas of expertise

Transfer pricing – Inbound and outbound planning assignments, profit/cash repatriation planning, value chain transformation or supply chain management projects, profit attribution to permanent establishments, etc.


Education and qualifications

  • Chartered Accountant, Institute of Chartered Accountants of India (ICAI)

  • Honours Graduate in Commerce

Professional Associations

  • Member of the Global Editorial Board of the magazine, Transfer Pricing Forum, published by Bloomberg BNA

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