COMPLIANCE

• Local transfer pricing compliance documentation for international transactions and specified domestic transactions including understanding of
  • Functional analysis
  • Comparability analysis
  • Industry and business overview
  • Case Studies
• Preparing Accountant’s Report in Form 3CEB and filing with Income Tax online portal.
• Master File and country wise reporting
  • Assistance in preparation
  • Assistance in communicating and Liaoning with the relevant authorities per need
  • Issuing comprehensive TP study

ADVISORY

• Assistance in setting up business/operational model
  • Restructuring of existing business model to build tax/commercial efficiencies
  • Due diligence report for business model and pricing arrangements of target acquisition.
• Dispute Avoidance/Resolution
  • Drafting and Representation before Transfer Pricing Officer, Commissioner of Income Tax (Appeals), Dispute resolution panel and Appellate tribunals.
  • Tax briefings and providing external support to counsels for representation before Higher Courts
  • Advance Pricing Agreements (APA) strategy and proceedings
    • Pre-APA planning – structure to be taken to the APA, preparation of transactional documents, reviewing intercompany agreements, etc
    • Assistance in pre-filing consultation, preparation and filing of application and responding to queries/questions sought
    • Assistance in dealing with APA authorities and obtaining draft and final APA agreements
  • Mutual Agreement Procedures (MAP)
    • Evaluation of facts
    • Reviewing Transfer Pricing documents and Transfer Pricing adjustment
    • Preparation of request for Competent Authority (‘CA’) and discussion if any.
    • Negotiation and closure of MAP
    • Testing