Transfer Pricing
Key Offerings
- Assists in developing and implementing viable Transfer Pricing policies.
- Restructuring of existing business model to build tax/commercial efficiencies.
- Initial Business Review
- Functional & Risk Analysis
- Analysis of Market and Industry
- Benchmarking / Economic Analysis
- Assistance in preparing global transfer pricing policy document
- Structuring management fee payments, royalty payments, intercompany financing arrangements
Strategies
- Providing in-house training, contract drafting, and billing methodologies
- Disclosure of International transactions between Associated enterprises.
- Review of Arms' length price of the International transactions.
- Review of the appropriate method for computing the Arms' length price.
- Business will have to comply with the Transfer Pricing rules and Documentation set with reference to the OECD (The Organization for Economic Cooperation and Development) Transfer Pricing Guidelines.
Compliance
- Issuance of Transfer Pricing study report
- Form 3CEB for Transfer Pricing Cases (both Corporate and Non Corporate)
- Country by Country Reporting (CBCR)
- Form 3CEAA Master File Part A and Part B
- Form 3CEAB
Policy and Controversy
- Assistance in Representation Before:
- a) Transfer Pricing Assessing Officer
- b) Commissioner of Income Tax (Appeals)
- c) Dispute Resolution Panel
- d) Income Tax Appellate Tribunal
- Drafting of submissions, appeals and letters to the revenue appellate authorities
- Assistance in relation to Safe Harbour Application
- Assistance with mutual agreement procedures (MAP)
