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Transfer Pricing Services

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 services

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

As part of our service, we cover all the important aspects related to direct taxation and their legal procedure. Our expert direct tax advice and observant strategies have helped many businesses to overcome their tax implications.

Our Services

Advisory services

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 Services 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