Designing Global Transfer Pricing Policy, evaluating business models, and identifying value drivers in the supply chain for optimal tax efficiency.

Preparation of Masterfile in accordance with country regulations, and comprehensive documentation for MNE groups to ensure BEPS compliance.

Proactive approach to eliminate future litigation for covered transactions through agreements between CBDT and taxpayers.

Conduct searches in databases (India and Foreign) to identify appropriate comparables for taxpayers with detailed analysis and reporting.

Evaluating applicability of safe harbour provisions to related party transactions, preparation and filing of safe harbour applications.

Preparation of detailed transfer pricing documentation (local file) for all countries, encompassing global documentation requirements.

Review the business model of the company, evaluate intercompany transactions in light of intercompany agreements and compliance requirements.

Formulate audit defense strategy before all forums (TPO, DRP, Commissioner of Income Tax Appeals, and Income Tax Appellate Tribunal).

Undertaking benchmarking study for arriving at the arm’s length prices for KMP payments, that involves comprehensive analysis and documentation.

Benchmarking Study for arriving at the arm’s length prices for interest rates using Global databases, that involves detailed financial analysis and compliance reporting.

Benchmarking Study for arriving at the arm’s length royalty for intangible property, that involves valuation analysis and compliance documentation.

Review of the documentation maintained by the company with regard to the intra-group payments for royalty and management charges, ensuring compliance and optimal structuring.

Identification and evaluation of Related Party Transactions to ensure arm’s length pricing and fair valuation in line with SEBI-LODR requirements. Support in presentation before Audit Committee.

Support companies to evaluate the impact of global minimum tax after evaluating QDMTT, IIR across various jurisdictions. Comprehensive analysis and strategic planning for tax optimization.

TP comfort letters, memos for auditors, identifying related parties and transactions, determining ALP, and comprehensive compliance support.