TaxPlanning

Transfer Pricing

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)