Transfer Pricing

  • 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
  • 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


Contact us here and we’ll get back to you as soon as possible.

  +91 11 26025140

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