TRANSFER PRICING ADVISORY
Designing intercompany policy, Drafting intercompany agreements, Price setting through benchmarking.
BENCHMARKING
Conduct searches in databases (India and Foreign) to identify appropriate comparables as that of the tax payer which involves:-
DUE DILIGENCE
Review of business model, intercompany transaction, previous years’ documents, TP orders, agreements, audit positions taken and offer advice to reduce the risk exposure.
SAFE HARBOUR
Evaluating the applicability of safe harbour provisions to the related party transactions, Preparation and filing of safe harbour application (form 3cefa in india)
TP DOCUMENTATION
Preparation of local files for various countries including benchmarking using global databases.
LITIGATION
Formulate audit defense strategy before all forums (TPO, DRP, Commissioner of Income Tax ( Appeals) and Income Tax Appellate Tribunal, Providing assistance in terms of preparation of written submissions / appeal documents
ADVANCE PRICING AGREEMENTS
Proactive way to eliminate future litigation for covered transactions once the agreement is signed between the cbdt and the tax payer, for 5 forward looking and 4 rollback years.
OTHER SERVICES
TP COMFORT LETTERS / MEMO FOR AUDITORS, FIN 48 ASSISTANCE – QUANTIFICATION OF TP EXPOSURE ON UNCERTAIN TAX POSITIONS,