An International Transaction entered into between two or more Associated Enterprises warrant compliance with the Transfer Pricing Regulations. Transfer Pricing Regulations are typically triggered when Associated Enterprises enter into commercial contracts during the course of business operations to allocate a particular cost incurred in relation with sales, service and facility. In essence, as your products, services, assets and property gets cross border, tax obligations become more complex.
In order to offer solutions that help you stay compliant, ensure operational efficiency and leverage on expert solutions and advice so as to maintain the much needed competitive edge, our Transfer Pricing planning, advisory, documentation and litigation support becomes an appropriate solution.
With ever increasing complexities in doing business and typical cross border planning and compliance requirements, what becomes extremely critical is ensuring appropriate prior planning, timely compliances, practical and technical guidance and updates and able assistance in dispute resolution.
Typical sequence of events in a Transfer Pricing Documentation assistance
Prescribed Transfer Pricing Documentation
Our Approach – Documentation Phases
Complete range of Transfer Pricing services available with us includes:
Operating structure review and functional analyses
Customized benchmarking analyses
Identify transfer pricing re-design options
Assistance in inter-company Agreements and other documentation
Mitigate business change impact on a company’s Transfer Pricing risk profile
Preparation of a robust Transfer Pricing policy
Aligning Transfer Pricing policy with commercial substance
Complete Transfer Pricing documentation assistance (international and domestic Transfer Pricing)
Identify strengths to deal with potential Transfer Pricing controversy
Complete assistance in representation before the Transfer Pricing Authorities (including the initial assessment stage, Appeal Stage (CIT(A) and ITAT) / Dispute Resolution Panel etc.
Put forth best defense in mitigating and minimizing the Transfer Pricing adjustments, if any, and associated interest and penalties, if any
Adherence to Transfer Pricing policy with strong back up documentation
Assistance in stages of an Advance Pricing Agreement, including feasibility analysis, conceptualization and applications (pre/post stages)
Assistance in Safe Harbor application and compliance related assistance
Complete advisory support
Permanent Establishment & Profit Attribution related assistance
Training and development customized for organizational needs
Aimed at helping global businesses achieve operational and international tax objectives and to protect tax base, eliminate double taxation and enhance cross border trade, seek Transfer Pricing services from experienced professionals in the field.