- Issuance of Accountant’s Report / Transfer Pricing Certification (Form 3CEB)
- Preparation of detailed transfer pricing documentation relating to international and specified domestic transactions
- Assistance and Preparation of Master File (Form 3CEAA & Form 3CEAB) and Country by Country Reporting (Form 3CEAC, Form 3CEAD & Form 3CEAE).
- Transfer Pricing Study / advisory for new transactions or specific transaction including Intangibles, Loans and Guarantees, Intra Group services, Payments Development Centers, R&D Centres, Restructuring or Reorganization, Purchase or sale of marketable securities etc.,
- Formulation and Implementation of domestic and global transfer pricing policies.
- Review of current operational structure: Evaluate whether contractual arrangements are in line with their operational arrangements (i.e. substance and form of international transactions are aligned).
- Benefits tests analysis for intra-group services: Review and evaluate the benefits that have arisen from the availing of / provision of such intra-group services.
MANAGING TRANSFER PRICING CONTROVERSY
- Assistance in the entire lifecycle of Advance Pricing Agreement (APA) comprising of pre-filing consultation, filing of APA application, negotiation and preparation of the mutually agreed draft agreement.
- Representation before Transfer Pricing Officer (TPO), Commissioner Income Tax (Appeals), Dispute Resolution Panel and Income Tax Appellate Tribunal
- Assistance in Mutual Agreement Procedure (MAP)
- Assistance in the application of Safe Harbour Rules
- We provide support for benchmarking under Transfer Pricing with Indian Databases including ProwessTM, Capitaline Plus, etc.
- We can provide benchmarking support from foreign databases such as (Amadeus, Royaltystat, Ktmine, etc.,) for foreign tested parties or for benchmarking special transactions.