top of page

Practice Areas

Tax and Legal
Corporate Advisory
Strategic Consulting

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.


  • 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


  • 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

How can we help you?

Email us:


Call us: +91 011 3000 4990

Meet our Tax Experts
Audit & assurance
Tax & Legal
bottom of page