Transfer Pricing

Compliance and Documentation

  • Functional analysis and testing the pricing policy through benchmarking analysis
  • Preparation of Transfer Pricing Study Report (TPSR)
  • Review and certification of segment P&L
  • Issuance of Accountants Report
  • Master File / CbCR compliances

Advisory

  • TP policy design through FAR analysis and implementation
  • Alignment of TP policy with actual business conduct through FAR interviews
  • Assistance in conducting a health check to identify potential gaps in the TP arrangements
  • Need benefit test (NBT) and documentation
  • Structuring management fee payments, royalty payments, inter-company financing arrangements
  • Custom and Transfer pricing policy alignment
  • Drafting/review of inter-company agreements
  • Review of Inter-company service mark-up
  • Global/Local benchmarking analysis

Litigation

  • Drafting submission and litigation support
  • Representation during Transfer Pricing audits, DRP and CIT(A)
  • Advisory on high-end litigation strategy
  • Assistance in APA strategy and related support
  • Safe Harbour application