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Transfer Pricing

Increased number of intercompany transactions has made transfer pricing a leading risk management issue for global businesses.

The litigation in India on account of this is humongous. We aim to facilitate companies by providing practical transfer pricing solutions that are aligned to their global business and objectives and also provide controversy management.

Our Transfer pricing team has technical expertise and knowledge to assist in transfer pricing matters for the clients which mainly includes:

Indian Transfer Pricing Support Advisory

  • Transfer Pricing Study/advisory for new transactions or specific transaction including
    • Intangibles
    • Loans and Guarantees
    • Intra Group services
    • Payments Development Centers
    • R&D Centres
    • Restructuring or Reorganization
    • Purchase or sale of marketable securities etc.
  • Development of better understanding of risks associated with transfer pricing (functions)
  • Formulation and Implementation of domestic and global transfer pricing policies

Managing Transfer Pricing Controversy

  • Assistance in all the stages the entire lifecycle of Advance Pricing Agreement (APA) comprising of pre filing consultation, filing of APA application, negotiation and preparation of mutually agreed draft agreement.
  • Representation before Transfer Pricing Officer (TPO), Commissioner Income Tax (Appeals), Dispute Resolution Panel and Income Tax Appellate Tribunal in the case of transfer pricing assessment or appeals
  • Assistance in Mutual Agreement Procedure (“MAP”)
  • Assistance in application of Safe Harbour Rules

Benchmarking Support

  • We provide support for benchmarking under Transfer Pricing with Indian Databases including ProwessTM, Capitaline Plus etc.
  • Through our global alliances we have the capability to provide international benchmarking support for Multinational Companies in the following global databases for foreign tested parties or for benchmarking special transactions
    • RoyaltyStat
    • Amadeus
    • KTMine
    • BvD

Compliance

  • Preparation of detailed transfer pricing documentation relating to international and specified domestic transactions
  • Issuance of Accountant’s Report / Transfer Pricing Certification (Form 3CEB)
  • Assistance and Preparation of Country by Country reports in accordance with OECD