Our Transfer Pricing team provides a range of services from provision of APA services to handling large global assignments including Country by Country reporting. We are providing client specific solutions i.e. planning, policy-making, implementation, robust documentation and compliance along assisting clients before the revenue and appellate authorities.
Compliance
Local transfer pricing compliance documentation for international transactions and domestic transactions including:
Functional analysis
Comparability analysis
Industry and business overview
Accountant’s Report in Form 3CEB
Country-by-country (CBC) reporting
Assistance in preparation of CBC report where:
The ultimate parent company is in India
The Indian entity is designated as the Alternative Reporting Entity (ARE)
Assistance in communicating and liasoning with the relevant prescribed authorities
Advisory
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
Assistance in corporate governance under companies act, 2013 and SEBI regulations
Review of deemed international transactions
Assistance in preparing profit attribution studies
Assistance in preparing global transfer pricing policy document
Dispute Avoidance/Resolution
Assistance in representation
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