TRANSFER PRICING

Transfer Pricing services in India

Multinational organisations are operating in an environment of unprecedented complexity. Increased inter-company transactions, both domestic as well as cross- border, in midst of evolving transfer pricing regulatory landscape with each country trying to maximise its share of tax revenue, accompanied by increased enforcement activities have made Transfer Pricing and determination of Arms Length price (ALP) a leading risk management issues for organizations.
In India, the ongoing enforcement of transfer pricing regulations in the country and adjustments being made focussing on new and more complicated issues have brought to the fore the reality that Transfer pricing controversies are expensive and time- consuming to deal with and frequently result in double taxation of income and lead to considerable uncertainty. Further, with the advent of Base Erosion and Profit Shifting (“BEPS”), transfer pricing is expected to become a focus area for India and other jurisdictions as well.
Our Transfer Pricing team provides a range of Transfer Pricing services in India from provision of Advance Pricing agreements to 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. Our Transfer Pricing services in Ahmedabad, Gujarat include the following:
Compliance
  • Transfer pricing compliance documentation for international transactions and specified domes-tic transactions including following analysis:
    • Functional
    • Assets
    • Risk and Industry overview
  • Preparation of 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
      • 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 authorities Advisory
  • Assistance in setting up business and structuring the 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
  • 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 ar-rangements
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