India & many developing countries have traditionally been strong advocates of source based taxation. In the context of transfer pricing, the spirit of OECD’s guidelines in terms of “Functions Assets and Risk” (FAR) Analysis has been practiced and reliance thereon is also upheld by the Indian Courts in many rulings. Rakesh Nangia, Managing Partner with inputs from Nitin Narang, Executive Director shares his views on market jurisdictions which create ‘value’ should be remunerated in addition to the outcome of FAR analysis for Taxsutra special series Tax Ring : Transitioning from FAR to FARM analysis Tax Sutra Special Series tax