In a move that will facilitate ease of business, domestic transfer pricing provisions will apply only if one of the parties to a deal is availing of tax benefits. Traditionally, transfer pricing applied to international transactions entered into by a company in India with related parties, such as its foreign parent company or overseas group companies. Pricing of the transaction had to be at arm's length — which refers to a true unbiased value — to ensure that India got its due share of tax. However, the Finance Act, 2012 expanded the ambit to cover domestic transactions (which included payment to directors) entered into by a company with related parties if the aggregate of such transactions in a year was over Rs 5 crore. The top-most challenge of India Inc was substantiating that directors' fees paid by it was at an arm's length. A director fee would depend on many factors, including size of the company, industry sector. Even Mukesh Ambani and Azim Premji were unlikely