Budget 2026: Structured dispute resolution tops tax reform wishlist

According to the survey results, 44% of respondents are pushing for faster resolution of tax disputes and the use of mediation, while 39% are demanding faster APA proceedings. Rationalizing corporate tax incentives for production and simplifying withholding tax provisions are also among the tax reforms they want.Also Read: Exporters’ budget wish list: tax sauces, inverted duty structure fix and more
Finance minister Nirmala Sitharaman will present the Budget 2026-27 on February 1.
All healthcare and pharmaceutical companies surveyed want resolution of tax disputes, while 70% of infrastructure companies want certainty in transfer pricing.
Stating that tax reforms will improve the robustness of litigation and dispute resolution in India, the survey found 34% of respondents noted accountability for high assessments and 32% wanted time-bound disposal of tax appeals.
83% of companies with revenues of ₹500-999 crore want accountability for tough evaluations. Officially accepting mediation in tax disputes and lowering preliminary deposit requirements for appeals are also among the reforms sought.
Companies with revenues above Rs 5,000 crore want all four reforms to be included in the upcoming budget. The survey covered 41 CFOs in companies with revenues of less than Rs 500 crore and more than Rs 10,000 crore, across healthcare and pharmaceuticals, technology, manufacturing, infrastructure, consumer goods and retail, and financial sectors.Also Read: Budget 2026: Industry leaders seek funding framework for innovation, R&D and MedTech in pharma
Gulf Cooperation Council reforms
When asked which tax reform would most accelerate the expansion of the global talent hub (GCC) in India, 51% of respondents preferred stronger and clearer transfer pricing safe harbor rules, while 22% cited faster APA processes. Simplified compliance and early growth during setup were requested by 15%, while 12% wanted clearer guidance on workplace rules.
India is home to more than 1,750 GCCs with approximately 2,975 units. More than 220 units are located in tier 2 and 3 cities; This reflects the Gulf Cooperation Council’s increasing centralization beyond its metropolitan centers.
“These GCCs together generated revenues of $64.6 billion in FY25. As per industry forecast, India’s GCC market is expected to reach $110 billion by 2030,” Jitin Prasada, minister of state for electronics and information technology, told the Lok Sabha last month.
He added that the number of Gulf Cooperation Council members in the country is expected to rise to around 2,400-2,550 by 2030.
According to an ET-PwC survey, at least a third of all industry segments surveyed want robust transfer pricing safe harbor rules. The demand was also echoed by all respondents in the ₹500-999 crore income range. Companies with turnover of ₹ 5,000 crore and above want reforms in all four tax areas for GCC growth.
With the aim of strengthening India’s Gulf Cooperation Council ecosystem, the latest budget provides states with support for World War II. announced that a national framework will be created to provide guidance on promoting the Gulf Cooperation Council in tier-1 cities. The framework will propose measures to increase the availability of talent and infrastructure, establish legal reforms and cooperation mechanisms with industry. The proposed national framework is intended to act as a facilitating and guiding mechanism for states. Fiscal incentives for the GCC are implemented through state-specific policies, while the union government is supporting the ecosystem through digital infrastructure, skills initiatives and ease of doing business reforms.Also Read: Budget 2026 is key for India to become world’s next innovation engine of Gulf Cooperation Council Countries
indirect tax
On customs reforms, 39% of respondents want to accelerate the end-to-end digitalization of customs processes and 34% want to liberalize the Manufacturing and Other Operations in Warehouse (MOOWR) scheme. The program allows manufacturers to import raw materials and capital goods without paying customs duties.
According to the survey results, more than a third of respondents in the banking, financial services and insurance (BFSI), consumer and retail, healthcare, manufacturing and technology sectors want the MOOWR scheme to be liberalized.
A fifth of respondents want an amnesty scheme to resolve old disputes and just 7% want harmonization of customs and transfer pricing valuations. Infrastructure and technology companies want reform in all these areas.
Interestingly, while digitalization of customs processes has been the sole focus area for companies with revenues below 500 billion rupees, companies in the 500-4.999 billion rupees range also want reforms in the MOOWR program and an amnesty scheme for old issues.


