Transfer pricing

Transfer pricing is one of the key aspects of global trade with multinational companies. Keeping abreast of transfer pricing rules is an absolute necessity. With globalization the tax authorities in each jurisdiction are constantly developing measures to protect and increase their tax base. They continue to allocate more resources to enforce their transfer pricing laws. This means the task of setting transfer prices for intercompany transactions is becoming more complex and fraught with risk. The situation increases the challenges for multinational companies, and global companies must work harder to avoid scrutiny from various tax authorities — even potential litigation. By carefully following transfer pricing rules and regulations, smart corporations can maintain an appropriate record of global transactions through adept documentation requirements.

We help you with:

• Transfer pricing planning, documentation and implementation
• Income tax assessment and appellate support
• Assistance with advance pricing agreements

Broadly the work would be divided into three steps – planning, documentation and execution/implementation.

Transfer Pricing Planning

It is critical to align tax strategy with your business goals and market developments. This plays a vital role in managing your overall tax burden.

We help you develop and implement strategies that :

• Align tax-planning objectives with business operations.
• Identify transfer pricing re-design options.
• Contribute to the management of effective tax rates.
• Mitigate business change impact on a company’s transfer pricing risk profile.
• Control risk of transfer pricing adjustments and associated interest and penalties.

Transfer Pricing Documentation

Tax authorities worldwide are imposing new, stricter documentation on transfer pricing arrangements. Revenue authorities are focusing more widely and intensely on transfer pricing issues.

The OECD recently published recommendations as part of its base erosion and profit shifting (BEPS) initiative that greatly expands the documentation burden on multinationals.

Our approach is designed to give your company an effective transfer-pricing regime:

1. We help you to manage risk within the current environment of transfer pricing regulations, with an objective pointofview to provide consistency when analyzing and documenting transactions between related parties.
2. We help you locate all of the cross-border services and the benefits received and provided for the purpose of documentation and a cross charge.
3. We stay on top of intercompany finance transactions such as loans, guarantees, and foreign exchange, debt instruments that need to be appropriately analyzed and documented.
4. We ensure that you have matched your transfer pricing practices toyour transfer pricing policies.

Transfer Pricing Implementation/Execution

Execution issues must be addressed across the entire transfer pricing lifecycle, from strategy and planning to implementation and documentation.

We provides our clients with proven advice on implementing policies & procedures that will effectively set, monitor and document intercompany transactions.

Issuance of an Accountants Report under Form 3CEB in accordance with the Income Tax Act/Rules

Section 92E of the Income Tax Act 1961 requires that international and specified domestic transactions between an India entity and its associated enterprises should be reported in an Accountants Report – Form 3CEBas prescribed by the Income Tax Rules. Form 3CEB with appropriate information about the transactions, method of transfer pricing adopted, the rationale etc. needs to be filed before the Income Tax authorities on a yearly basis within the prescribed due date.

We assists your company’s tax team in preparing and e-filing the Form 3CEB with the Income Tax authorities and preparing the underlying supporting documents thereof.