Transfer Pricing
- Assistance in Transfer Pricing (TP) documentation for international / domestic transactions including preparation and maintenance of Local File, Master File and CbCR
- Assistance in obtaining TP Certification as required to be furnished with respect to international / domestic transaction
- Undertaking TP planning study for proposed related party transactions, for determining Arm’s Length Price (ALP) of proposed transaction with an Associated Enterprise (AE), to ensure that appropriate margins are agreed upfront to comply with TP regulations
- Representation in assessment and appellate proceedings including proceedings before the Income Tax Appellate Tribunal (ITAT) and the Dispute Resolution Panel (DRP)
- Assistance in undertaking consultations with Revenue authorities on Mutual Agreement Procedure (MAP) for TP disputes and Advance Pricing Agreement (APA) proceedings. These proceedings help in resolving long standing disputes with tax authorities and providing future certainty with respect to transactions with AEs
- Advising on safe harbour regulations, thin capitalization rules and secondary adjustment norms under TP provisions
- Assisting clients on value and supply chain management from a TP Perspective. This entails designing of pricing arrangements through supply chain, keeping in mind the substance embedded within respective entities, as against artificial allocation of functions, assets and risks