International workers from these countries posted to India are not required to contribute to THE social security systems run by PFOA in India. The Indian transfer pricing authorities have already adopted the OECD approach to INTANGIBLE returns of BEPS and agree that these returns should be held by the entity that makes strategic decisions about the creation of intangible assets, not by the entity that simply owns the ownership of the securities and financing capabilities. Therefore, India considers that the separation between profit and economic activity can be significantly separated by adopting the “functions of important persons” approach in determining the economic beneficiary of intangible assets. He also stated that Indian workers, who work purely temporarily in Singapore and are covered by EPFO-managed social security systems, are also exempt from compulsory contributions in Singapore. Indian transfer pricing rules apply to international transactions and certain domestic transactions between related companies. Regulations have evolved over the years and are now intended to cover the following debts in commercial transactions; restructuring or restructuring of companies (whether or not this affects current year`s earnings, revenues, losses or assets); Intangible assets, including the marketing of intangible assets, human assets or technology-related intangible assets, etc. Following the introduction of the Advance Pricing Agreement (APA) in 2012, the rules for returning to the APA were launched in 2015. As a result, APA can now offer security in India for up to a 9-year period. Indian workers who have been posted to the 17 countries with which it has signed social security agreements enjoy a similar privilege. However, there are a large number of countries with which India has no social security agreements. This is why workers in these countries are required to subscribe to THE EPFO programs and, at some point, they carry out these mandatory programs in their countries. A senior EPFO official said that the clause clearly states that Singaporeans, who work purely temporarily or in the short term and are part of the social security system in their own country, are not subject to these EPFO-managed systems. Workers in these countries must present a certificate of coverage stating that they are covered by such social protection systems in their country and be exempt from the contribution to EPFO systems.

In addition, India has social security agreements with 17 countries – the Netherlands, Belgium, Germany, Switzerland, Denmark, Luxembourg, France, South Korea, Sweden, the Czech Republic, Austria, Finland, Japan, Canada, Australia, Norway and Hungary.