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.

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Compliance

• Local transfer pricing compliance documentation for international transactions and specified domestic transactions including:

  • Functional analysis

  • Comparability analysis

  • Industry and business overview

• Assistance in obtaining of an Accountant’s Report in Form 3CEB

• Master File and country-by-country (CbC) reporting

  • Assistance in preparation of Master File

  • Assistance in preparation of CbC Report where:

    • The ultimate parent company is in India

    • The Indian entity is designated as the Alternative Reporting Entity (ARE)

    • Indian entity does not have an agreement for exchange of CbC Report with country of foreign parent

    • Despite having an exchange agreement, country of foreign parent (or ARE) fails to share CbC Report

  • Assistance in communicating and liasoning with the relevant prescribed authorities whenever required
     

Advisory

• Assistance in setting up business/operational model

• Restructuring of existing business model to build tax/commercial efficiencies

• 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

• Assistance in corporate governance under Companies Act, 2013 and SEBI regulations

  • Identification of related parties

  • Analysing the identified RPT as to:

    • Whether the transactions are in the ordinary course of business; and

    • Whether the transactions are proposed to be undertaken on arm’s length basis

  • 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

  • Review-related party compliances under the Companies Act on a quarterly/half-yearly/annual basis

  • Present our analysis at board meetings to assure Directors that compliances are in order

• Review of deemed international transactions

• Assistance in preparing profit attribution studies

• Assistance in preparing global transfer pricing policy document

• Supply chain restructuring

• Structuring management fee payments, royalty payments, inter-company financing arrangements
   

Dispute Avoidance/Resolution

•  Assistance in representation before:

  • Transfer Pricing Officer

  • Commissioner of Income Tax (Appeals)

  • Dispute resolution panel

  • Appellate tribunals

• Drafting of submissions, appeals and letters to the revenue/appellate authorities

• Tax briefings and providing external support to external counsels for representation before High Courts and Supreme Court

• Assistance in Advance Pricing Agreements (APA) proceedings

• Assistance with mutual agreement procedures (MAP)

• Assistance in relation to Safe Harbour application