BEPS RELATED SERVICES

► PREPARATION OF MASTERFILE IN ACCORDANCE WITH THE COUNTRY REGULATIONS :-

• Preparation of master file document for MNE group as per the format prescribed by the OECD, Indian Regulations or any other jurisdiction.
• • Customization of existing MNE group ‘s master file for the purpose of the local group transfer pricing compliance.
  • Preparation of the relevant Formsfor the MNE which entails:-

Group Structure

• • Understanding group structure
  • Understanding the business operations of operating entities
  • Understanding the key drivers and policies in place

FAR Analysis

• • Understanding the business strategy of the group
  • Understanding the functions performed, assets employed and risks borne by each entity

Master File Contents

• • Develop a detailed understanding on the following:

• • • Group overview
    • Business of the Group
    • Intra Group policies
    • Intangibles
    • Financing arrangements
  • Prepare master file based on the above understanding and analysis
• Review of the group master file in light of the respective coutry requirements and providing inputs w.r.t. alignment of the local file and master file.

► Support for country by country reporting where the consolidated Turnover of the Multinational Group exceeds EUR 750 million

• Preparation of Country-by-Country report (CbCR) for the MNE Group as per the format prescribed by the OECD, and agreed by Inclusive framework countries.
• Preparation of the relavt form as per the parent entity jurisdiction  and assistance in filing with the Tax authorities.
• Review of the three tier documentation – CbCR, Master File and Local file, undertaking gap analysis to identify any inconsistencies and providing inputs on alignment the three-tier documentation with the facts of the MNE Group.

► Risk assessment of the Group’s transactions based on the key parameters

► IP Structuring/ DEMPE Analysis

• • Identify the intangibles used and the economically significant risks associated with DEMPE;
  • Identify the full contractual arrangements, with an emphasis on legal ownership, rights and obligations, including assumption of risks;
  • Identify the parties performing functions, using assets and managing risks related to DEMPE;
  • Confirm consistency between the contractual terms and the parties’ conduct and determine whether the party assuming economically significant risks controls and has the financial capacity to assume those risks, applying the risk guidance;
  • Delineate the actual controlled transactions related to the DEMPE of ip; and
  • Price the delineated transactions.