M D GUJRATI & CO.
Chartered Accountants
Practice Areas
Like an artist's art, our services are crafted as per your needs. This is what keeps us relevant, close to clients and a value figure in all our discussions.
Transfer Pricing
Our Transfer Pricing team provides a range of services from provision of APA services to handling large global assignments including Country by Country reporting. We are a dynamic organisation assisting clients in corporate decision-making at different stages of inter-company transactions by providing tailored solutions i.e. planning, policy-making, implementation, robust documentation and compliance along assisting clients before the revenue and appellate authorities.
Compliance
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Local transfer pricing compliance documentation for international transactions and specified domestic transactions including:
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Functional analysis
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Comparability analysis
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Industry and business overview
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Assistance in obtaining of an Accountant’s Report in Form 3CEB
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Master File and country-by-country (CbC) reporting
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Assistance in preparation of Master File
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Assistance in preparation of CbC Report where:
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The ultimate parent company is in India
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The Indian entity is designated as the Alternative Reporting Entity (ARE)
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Indian entity does not have an agreement for exchange of CbC Report with country of foreign parent
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Despite having an exchange agreement, country of foreign parent (or ARE) fails to share CbC Report
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Assistance in communicating and liasoning with the relevant prescribed authorities whenever required
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Advisory
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Assistance in setting up business/operational model
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Restructuring of existing business model to build tax/commercial efficiencies
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Due diligence report (DDR) assistance from transfer pricing perspective in order to ensure that the business model and pricing arrangements of target acquisition are defensible
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Assistance in corporate governance under Companies Act, 2013 and SEBI regulations
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Identification of related parties
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Analysing the identified RPT as to:
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Whether the transactions are in the ordinary course of business; and
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Whether the transactions are proposed to be undertaken on arm’s length basis
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Analysing and evaluating various approvals that may be required (i.e. Audit Committee, Board of Directors, shareholders etc.) for each of the RPT under the Companies Act 2013 and SEBI regulations
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Review-related party compliances under the Companies Act on a quarterly/half-yearly/annual basis
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Present our analysis at board meetings to assure Directors that compliances are in order
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Review of deemed international transactions
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Assistance in preparing profit attribution studies
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Assistance in preparing global transfer pricing policy document
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Supply chain restructuring
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Structuring management fee payments, royalty payments, inter-company financing arrangements
Dispute Avoidance/Resolution
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Assistance in representation before:
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Transfer Pricing Officer
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Commissioner of Income Tax (Appeals)
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Dispute resolution panel
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Appellate tribunals
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Drafting of submissions, appeals and letters to the revenue/appellate authorities
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Tax briefings and providing external support to external counsels for representation before High Courts and Supreme Court
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Assistance in Advance Pricing Agreements (APA) proceedings
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Assistance with mutual agreement procedures (MAP)
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Assistance in relation to Safe Harbour application