TAX

Transfer Pricing

Any cross-border transaction between two related parties is subject to transfer pricing provisions in India. Over the years, the Transfer pricing regulations are becoming increasingly complex. The last several years witnessed substantial litigation on Transfer Pricing related issues. Further, with the advent of –

  • Base Erosion & Profit Shifting (BEPS)

the complexity of Transfer pricing would be further enhanced. Given this, it is imperative for businesses today to align their related party transactions with acceptable Transfer Pricing policies.

At Transaction Square

We understand the
complexity of
Transfer pricing

With rich experience and a global partner network, we provide end-to-end transfer pricing services to our clients. Our services encompass – transfer pricing planning for new related party transactions proposed, transfer pricing benchmarking and transfer pricing documentation (as statutorily prescribed) for all international transactions between related parties. Our teams also extend end-to-end litigation support as well on all transfer pricing matters. Many multinationals are evaluating the route of seeking an Advance Pricing Agreement for their related party transactions in India.

Transfer Pricing Offerings

Consulting and Advisory

  • Setting up / restructuring of business models to build tax / commercial efficiencies
  • Conducting health check to identify potential gaps in the transfer pricing arrangements
  • Due diligence report (DDR) assistance
  • Benchmarking analysis

Compliances

Assistance in multi-jurisdictional filing and documentation related compliance requirements including preparation of Master File and Country by Country Report

Companies Act and SEBI Regulations

Assistance in Corporate governance under Companies Act, 2013 and SEBI regulations including review of related party compliances on a quarterly/ half-yearly/annual basis

Dispute Resolution

Assistance in representation before Transfer Pricing Officer, Commissioner of Income Tax (Appeals), Dispute Resolution Panel, Appellate Tribunals, and higher levels.

Advance Pricing Agreement, Mutual Agreement Procedure and Safe Harbour

Assistance in strategising, preparation, filing and representation for APA, MAP and Safe Harbour

Our experienced team and network partners specialize in,

Identifying

Identifying the right approach for proposing the pricing for related party transactions as may be acceptable to the regulators

Strategizing

Assistance in strategizing the APA

Presenting

Appropriate presentation of the application and representation of matter before relevant APA authorities.

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Transfer Pricing Survey

Take a survey​

A short survey on Transfer Pricing

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