Transfer Pricing

Transfer Pricing

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.