Transfer Pricing
In a global economy where multinational enterprises (MNEs) play a prominent role, transfer pricing continues to be high on the agenda of tax administrations and taxpayers alike. For taxpayers, it is essential to limit the risks of economic double taxation that may result from a dispute between two countries on the determination of the arm’s length remuneration for their cross-border transactions with associated enterprises.
- A well-managed lifecycle approach to transfer pricing allows companies to access efficient tax planning and cash flow optimization opportunities.
- Our Transfer Pricing professionals are engaged with our clients through every stage of the transfer pricing lifecycle which includes –
– Intercompany planning and design,
– It’s efficient and accurate implementation that increases shareholder confidence,
– All while prioritizing compliance and managing risk.
Once the International Transactions are entered throughout the year, it is imperative to undertake the Transfer Pricing Documentation to record the Arm’s Length Price and Comparability Analysis post the year end. Such an analysis is the ultimate proof that the transactions entered between the Associated Enterprises are at an Arm’s Length Price and there is no potential tax avoidance or tax risks.
We have helped our clients for the following services –
- Indian transfer pricing documentation,
- Global transfer pricing documentation,
- Drafting of Function, Asset and Risk analysis (FAR),
- Drafting of company and group overview,
- Industry analysis for the industry in which they are operating,
- Determination of Arm’s Length Price, and
- Comparability analysis.
In Transfer Pricing, the defense mechanism from the Taxpayer’s perspective is an essential element where the Tax Authorities calls for Transfer Pricing Documentation where an Arm’s Length nature of transaction needs to be proven.
Our solution in the Transfer Pricing dispute resolution includes –
- Transfer Pricing Representation before Tax authorities
- Advance Pricing Agreements
- Safe Harbour Representations
- Transfer Pricing Litigation