An expert has highlighted India and Canada as the nations with the most aggressive transfer pricing policies.

Sean Foley, global leader for global transfer pricing services at KPMG, revealed that rules in this area of taxation are prevalent in around 85 countries, but the level of scrutiny varies considerably.

In an interview with the Economic Times, he discussed the impact of transfer pricing regulations in India in particular.

Mr Foley said he does not expect the nation's authorities to attempt to tax multinationals retrospectively, although they may have access to the data necessary to do so.

"I would anticipate that it won't have a retroactive effect, but certainly some impact. The Indian government has been criticised for retroactivity in the past," he stated.

The expert also discussed the possible implications of the introduction of base erosion and profit sharing (BEPS). He said the biggest impact of this would be the requirement for multinationals to provide country-to-country reporting.

"For the very first time, a company will have to explain what its global transfer pricing approach is," Mr Foley stated.

He added that revenue authorities will soon have greater contextual information regarding transactions across borders and businesses will need to consider this carefully.

Mr Foley also warned the introduction of BEPS and a more aggressive focus on transfer pricing will see the risk of multinationals being hit with double tax increase.

India is arguably the nation where transfer pricing action has generated the most headlines. A number of household names have been involved in disputes in the country, including the likes of Shell and Vodafone, both of which emerged victorious from their respective cases.