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Transfer pricing

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

Assistance in setting up business/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

Assistance in corporate governance under Companies Act, 2013 and SEBI regulations

    • Identification of related parties
    • Analysing the identified RPT as to
      • Whether the transactions are in the ordinary course of business; and
      • Whether the transactions are proposed to be undertaken on arm’s length basis

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 before:
    • Transfer Pricing Officer
    • Commissioner of Income Tax (Appeals)
    • Dispute resolution pan
    • elAppellate 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