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TRANSFER PRICING SERVICES 

Transfer Pricing has become a very important subject in the board room of multinationals. It has evolved over a period of time from merely a compliance to a tax planning and tax mitigation subject. Any cross-border transactions between associated entities are subject to transfer pricing globally and in India. India introduced transfer pricing regulations way back in 2002 and has sharpened over a period of time. Over the years, Transfer Pricing regulations are becoming increasingly complex globally. Last several years witnessed substantial litigation on Transfer Pricing related issued and with the advent of BEPS Action Plans, complexity of Transfer Pricing would further enhance. Given this, it is imperative for businesses to align their related party transactions with acceptable Transfer Pricing policies. Developments on the policy front, including the introduction of “Safe Harbor” norms, Advance Pricing Regime, etc. would certainly help organisations to achieve more certainty in their transfer pricing matters.

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Our team has significant experience in transfer pricing matters and have worked on developing and implementing complex transfer pricing solutions for clients in several sectors. We help businesses in developing and implementing transfer pricing strategy and policies as well as in preparation of transfer pricing documentation (including for meeting CBCR requirements) and compliance. We also have extensive experience in transfer pricing dispute management and assisting clients with successfully concluding Advance Pricing Agreements (both unilateral and bilateral) to achieve certainty and mitigate against tax litigations.

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We provide a complete bouquet of services to clients in achieving their business goals of arranging inter and intra group transactions at “arm’s length” both from commercial stand point and from transfer pricing stand point. Our services comprise of:

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TRANSFER PRICING STRATEGY AND PLANNING

  1. Review of holding and capital structure to suggest efficient structures

  2. Review of supply chain as well as inter and intra group business transactions to integrate tax aspects with business objectives

  3. Evaluation of applicability and impact of transfer pricing regulations in different countries and assisting in evolving as well as implementing global transfer pricing policy

  4. Transfer pricing strategy and planning

  5. Assisting in developing SOPs, Controls and Governance aspects to minimise overall tax cost and mitigate business risks

  6. Advising on transfer pricing methodologies to be applied across different countries

  7. Assisting in training business and operations team to ensure compliance with complex transfer pricing regime

 

TRANSFER PRICING BENCHMARKING

  1. Carrying out Functions, Assets and Risk (‘FAR’) Analysis of various businesses and transactions

  2. Benchmarking of various inter and intra group transactions using local and global database as well as tools

  3. Preparing a detailed FAR analysis and benchmarking report to determine appropriate transfer pricing method and arm’s length pricing

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TRANSFER PRICING DOCUMENTATION

  1. Advising and assisting in preparing as well as concurrently maintaining global transfer pricing documentation

  2. Advising and assisting in preparing as well as concurrently maintaining local documentation including CbyC reporting in India as well as in other countries

  3. Assisting in developing SOPs, Controls and Governance aspects to ensure maintenance of required documentation both for business and transfer pricing compliance standpoint

  4. Assisting in training business and operations team to ensure maintenance of documentation on concurrent basis

 

TRANSFER COMPLIANCE AND RISK MITIGATION

  1. Advising on obtaining Advance Rulings from Authority for Advance Rulings in India – either unilateral or bilateral to obtain certainty and mitigate against litigation risk

  2. Assisting in preparing in filing various transfer pricing documents and returns to be filed with the Indian tax authorities

  3. Advising and assisting in representing before the tax authorities in relation to transfer pricing assessments, appeals, tax enquiries, enforcements, search & survey or any other proceedings in relation to cross border investments and transactions

  4. Advising and assisting in making submissions as well as representing before the appellate authorities, Tribunals, High Court & Supreme Court through appropriate Counsels, etc. in relation to cross border investments and transactions

  5. Advising and assisting in providing response as well as submissions to various kinds of notices received from the transfer pricing authorities and representing client before tax authorities in relation to cross border investments and transactions

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