Transfer Pricing

Our Transfer Pricing Division assists Indian and multinational corporations to develop and implement economically justifiable transfer pricing policies and documentation helping businesses navigate the complexities of transfer pricing regulations, reducing litigation risks and allowing senior management to focus on core operations effectively. We assist in developing and implementing viable transfer pricing policies, harmonization of existing ones and adopting new transfer pricing structures or alignment of prices with business restructuring.

We provide an effective, integrated organization-wide strategy for managing various complex Transfer Pricing issues involved with inter-company transactions involving goods, services and intangibles. With expertise in serving diverse sectors, including listed companies, our dedicated Transfer Pricing team offers end-to-end, customized solutions to serve the specific nature and scope of both international and domestic related-party transactions.

Services

Transfer Pricing Compliance

Reviewing transfer pricing positions and international transactions. 
Analyzing group structure and industry to assess functions and risks. 
Determining the best method for arriving at arm’s length pricing for transactions. 
Conducting economic and financial analysis on selected comparables. 
Pricing analysis for tangible and intangible goods, intercompany services, and financial transactions. 
We help maintain robust documentation and issue the Accountant’s Report (Form 3CEB) in compliance with the Indian Income Tax Act, 1961.

Transfer Pricing Planning and Supply Chain Restructuring 

Transfer Pricing planning aims to align business and pricing models, reducing risk and tax costs. Supply Chain structuring minimize compliance expenses and penalties. Our services include developing and implementing policies, harmonizing existing ones, and adjusting structures to business changes.

Our Transfer Pricing planning and supply chain structuring services include the following:

Litigation Support / Transfer Pricing Controversy Management 

Our controversy management services focus on helping clients develop strategic responses to tax disputes. We collaborate with you to devise strategies and practices for handling audit and appeal proceedings, whether before the Transfer Pricing Officer (TPO), Dispute Resolution Panel (DRP), Commissioner of Income Tax (Appeal), Income Tax Appellate Tribunal (ITAT), or High Court(HC).

Advance Pricing Arrangements (APA) 

The Finance Act of 2012 introduced the APA scheme, ensuring certainty in Transfer Pricing matters. APAs are agreements between taxpayers and tax authorities determining the most appropriate Transfer Pricing method or Arm's Length Price (ALP) for covered years. To address recurring Transfer Pricing disputes, the APA scheme was enhanced in the Finance Act offfm20iz1a4twioitnh rollback provisions. The CBDT encourages taxpayers to consider APAs to manage potential Transfer Pricing controversies for up to nine years. We assist in all stages, from pre-filing consultation to strategy development and negotiation with tax authorities.

Mutual Agreement Procedure (MAP)  

The Mutual Agreement Procedure (MAP) offers an effective resolution for complex Transfer Pricing disputes. India's extensive tax treaties with over 70 countries provide access to MAP proceedings under most agreements. Our Transfer Pricing team is adept at assisting clients with MAP applications for multinational corporations (MNCs).

FIN 48 Assistance 

FIN48 mandates companies to acknowledge, assess, display, and disclose uncertain tax and Transfer Pricing stances related to open tax years, encompassing the positions adopted or anticipated in their tax filings. It significantly impacts intricate tax realms and entails demanding practical and technical implications, subject to scrutiny by auditors.

Our Transfer Pricing experts offer tailored support to identify and evaluate your FIN48 Transfer Pricing risk and uncertain tax stance.

Transfer Pricing Valuation Services 

Restructuring of operations/ investments would need to be compliant with Transfer Pricing, Tax and other regulations with the values of the assets/ business proposed to be transferred being one of the key constraints determining compliance of Transfer Pricing and other regulations.

Our team assists entities to operate/ restructure their business operations/ investments/ intangibles within a Transfer Pricing compliant framework and assists in carrying out valuations of shares/ businesses/ intangibles.

Re-alignment of existing Transfer Pricing documentation as per BEPS 

The three-tier documentation enhances transparency for tax authorities, making deviations from transfer pricing policies more evident globally. Multinational Enterprises (MNEs) must assess existing data and inconsistencies to ensure compliance. We help align Transfer Pricing models with BEPS Action 13 standards to mitigate risks and tax costs.

Transfer Pricing Compliance

Reviewing transfer pricing positions and international transactions. 
Analyzing group structure and industry to assess functions and risks. 
Determining the best method for arriving at arm’s length pricing for transactions. 
Conducting economic and financial analysis on selected comparables. 
Pricing analysis for tangible and intangible goods, intercompany services, and financial transactions. 
We help maintain robust documentation and issue the Accountant’s Report (Form 3CEB) in compliance with the Indian Income Tax Act, 1961.

Transfer Pricing Planning and Supply Chain Restructuring 

Our Transfer Pricing planning and supply chain structuring services include the following:

Litigation Support / Transfer Pricing Controversy Management 

Advance Pricing Arrangements (APA) 

The Finance Act of 2012 introduced the APA scheme, ensuring certainty in Transfer Pricing matters. APAs are agreements between taxpayers and tax authorities determining the most appropriate Transfer Pricing method or Arm’s Length Price (ALP) for covered years. To address recurring Transfer Pricing disputes, the APA scheme was enhanced in the Finance Act offfm20iz1a4twioitnh rollback provisions. The CBDT encourages taxpayers to consider APAs to manage potential Transfer Pricing controversies for up to nine years. We assist in all stages, from pre-filing consultation to strategy development and negotiation with tax authorities.

Mutual Agreement Procedure (MAP)  

The Mutual Agreement Procedure (MAP) offers an effective resolution for complex Transfer Pricing disputes. India’s extensive tax treaties with over 70 countries provide access to MAP proceedings under most agreements. Our Transfer Pricing team is adept at assisting clients with MAP applications for multinational corporations (MNCs).

FIN 48 Assistance 

Our Transfer Pricing experts offer tailored support to identify and evaluate your FIN48 Transfer Pricing risk and uncertain tax stance.

Transfer Pricing Valuation Services 

Re-alignment of existing Transfer Pricing documentation as per BEPS 

Direct Tax and Regulatory

Our firm provides comprehensive Corporate Tax services aligned with Indian Income Tax Laws, helping businesses identify tax planning opportunities, minimize tax liabilities, and optimize outcomes through business reorganizations.

In the area of International Tax, our team delivers integrated tax solutions for multinational enterprises, addressing cross-border expansion, transaction flows, group restructuring and more. We specialize in structuring outbound and inbound transactions, managing cross-border financing, dividend repatriation, and ensuring efficiency in supply chains, while also offering expert support in international tax dispute resolution.

Our Regulatory Advisory services cover Exchange Control (FEMA & FDI Policy), entity setup and liquidation, and obtaining statutory registrations and operational licenses. We provide company secretarial support and help clients secure central and state incentives like PLI, SPECS, and M-SIPS, along with drafting corporate policies and legal agreements to ensure compliance.

In Representation & Litigation Support, our experts offer end-to-end services, representing clients before Indian tax authorities, appellate forums, and courts, ensuring effective resolution of disputes and support in Advance Rulings.

Transfer Pricing

Our Transfer Pricing services support Indian and multinational corporations in developing and implementing robust, economically sound transfer pricing policies and documentation. We offer comprehensive strategies to manage complex transfer pricing issues arising from inter-company transactions involving goods, services, and intangibles. Our services include Transfer Pricing Compliance with Three-Tier Documentation, Transfer Pricing Planning and Supply Chain Restructuring, and Litigation Support for managing transfer pricing disputes. We assist with Advance Pricing Arrangements (APA), Mutual Agreement Procedures (MAP), FIN 48, and Transfer Pricing Valuation Services. We also help realign existing transfer pricing documentation in line with BEPS requirements.

GST, Indirect Taxes, Customs & Foreign trade policy

We provide a comprehensive range of indirect tax services across multiple sectors, assisting multinational and domestic clients with indirect tax optimization strategies. Our team of indirect tax experts with deep industry knowledge offer sector-focused expertise, providing litigation support, representation before judicial authorities, advance rulings, anti-profiteering studies, due diligence, refund processing, tax health checks, credit reviews, and audit support. Our experts stay updated on tax policy changes, identifying risks and opportunities to deliver innovative solutions under GST, Foreign Trade Policy, Customs Act, and more.

Global Mobility Services

We provide comprehensive Global Mobility Services to multinational corporations, assisting in the mobilization of expatriate employees and ensuring compliance with Indian tax and social security laws. Our offerings include advisory on assignment structures, planning for employee assignments before arrival in India, and ongoing support throughout their stay. We address BEPS and PE risks, assist with secondment agreements, advise on tax-friendly compensation and ESOP structures, and guide on tax exemptions and foreign tax credits. We also offer immigration support, compliance with tax and social security regulations, and litigation services in case of audits or disputes with tax authorities.

 Private Client Services and Family Offices

Preservation and maximizing personal and family wealth involve various tangents such as personal aspirations, family dynamics and other socio-economic factors. All this warrants a distinct approach and bespoke and tailored solutions of trusted advisors.

Our firm has a strong focus on Private Client Services, offering deep insights into the unique needs of promoters and entrepreneurs. With years of experience, we act as trusted advisors, guiding clients through the complexities of their personal and business life cycles. We assist with family offices, succession planning, aligning group structures for value consolidation, and facilitating investment enablement. Our services also include planning for family assets, residential status and other specialized needs.