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.


  • 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?

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Call us: +91 011 3000 4990

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M D Gujrati & Co. is a registered partnership firm under the Indian Partnership Act, 1932 and a recognised chartered accountancy firm by the Institute of Chartered Accountants of India (ICAI).


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