Archive · 3 Oct 2026
India Needs Stronger Mechanisms to Improve Tax Certainty
The article says many people and businesses in India are unsure how tax rules will apply to them.
It cites a survey in which 96% of respondents said taxes in India were very or somewhat uncertain.
One reason is that taxpayers may not be able to get a clear answer before making a business decision.
Another is that tax disputes can take a long time to finish.
The author says India should make it easier to get advance rulings on tax questions.
The article also suggests speeding up appeals and helping officials handle complicated cases.
It says courts should decide issues that keep causing repeated disputes more quickly.
Clearer government guidance could help taxpayers understand how rules are meant to work.
A 2024 survey cited in the article found 96% of respondents considered tax in India very or somewhat uncertain.
The article identifies limited access to advance tax rulings and lengthy litigation as major sources of uncertainty.
It says the Board for Advance Rulings has been ineffective, while proposing a stronger, expanded advance-ruling mechanism.
Recommendations include reducing appeal backlogs, improving staffing and jurisdiction transfers, and supporting fairer Dispute Resolution Panel decisions.
The author also calls for faster resolution of recurring issues by the Supreme Court and clearer tax department guidance.
- Who
- Indian taxpayers and businesses, the tax administration, and tax dispute bodies.
- What
- An opinion article argues for reforms to reduce tax uncertainty and prolonged litigation in India.
- When
- The article refers to a 2024 survey and measures taken in recent years; it gives no publication date.
- Where
- India.
- Why
- The author says taxpayers lack effective ways to obtain clarity in advance, while appeals and litigation can take years.
- Survey finding
- 96% of respondents considered tax in India very or somewhat uncertain, according to the article's account of the survey.
- Survey cited
- Michael P. Devereux's 2024 paper, “What creates tax uncertainty-evidence from 3 phases of cross country survey”.
- Advance Pricing Agreement scheme
- Launched in 2013; the article says it addresses transfer-pricing issues.
- Proposed advance-ruling reform
- Expand case-specific rulings, potentially with a monetary threshold, binding on both the tax authority and applicants.
- Appeal backlog proposals
- Prioritize high-demand and older appeals, ensure full staffing and stable tenures, and transfer cases to the correct jurisdictions.
- International dispute resolution
- The article says India and Japan received the OECD Tax Certainty Award in 2019 and 2025 for resolving the highest number of transfer-pricing cases.
- Further proposals
- The author calls for fairer dispute panel decisions, faster decisions on recurring court issues, and tax department circulars or guidelines clarifying ambiguous rules.