Services

Valuation analysis for determining the arm’s length price of shares and business interests transferred between related parties

Our share valuation assistance involves:

• Understanding the nature, purpose and commercial circumstances of the related-party transaction
• Reviewing the rights, preferences and restrictions attached to the shares
• Analysing the historical financial performance and future business projections of the company
• Assessing the company’s business model, industry, growth prospects and key value drivers
• Selecting the most appropriate valuation methodology based on the nature of the business and availability of reliable information
• Valuation of equity shares in listed, unlisted and closely held companies
• Valuation of minority and controlling interests transferred between associated enterprises
• Valuation support for internal restructuring and changes in group ownership
• Undertaking sensitivity analysis for key financial and commercial assumptions
• Arriving at an appropriate arm’s length value of the shares
• Preparation of a detailed valuation report

Valuation analysis for determining the arm’s length value of intellectual property transferred, licensed or otherwise made available between related parties

Our IP valuation assistance involves:

• Understanding the nature of the intangible property (technology/brand) and the related-party transaction
• Identifying the legal ownership and economic ownership of the intangible
• Analysing the Development, Enhancement, Maintenance, Protection and Exploitation, or DEMPE, functions performed by the associated enterprises
• Assessing the historical financial performance, projected cash flows, useful life and commercial potential of the intangible
• Selecting the most appropriate valuation methodology based on the nature of the intangible and availability of reliable information
• Valuation of intangibles transferred as part of a business restructuring
• Undertaking sensitivity analysis for key financial and commercial assumptions
• Arriving at an appropriate arm’s length value for the intangible property
• Preparation of a detailed valuation report

Pillar Two Managed Service by VSTN combines technology, tax expertise, and ongoing compliance support to help multinational groups manage GloBE calculations, GIR reporting, data collection, regulatory monitoring, and global filing obligations through a single end-to-end solution. profice descriptive line for this

Why Choose VSTN Pillar Two Managed Service?

• End-to-End Pillar Two Compliance Management
  • From data collection to final reporting and filing support.
• Automated GloBE Calculations
  • Accurate calculation of ETR, Top-up Tax, QDMTT, IIR, and UTPR.
• Centralized Global Data Collection
  • Securely gather and validate data from entities across multiple jurisdictions.
• GIR & Reporting Support
  • Generate Pillar Two reports and Global Information Return (GIR) outputs with confidence.
• Regulatory Monitoring & Updates
  • Stay compliant with evolving OECD guidance and country-specific legislation.
• Dedicated Tax & Technology Experts
  • Access to specialists for technical interpretation and ongoing compliance support.
• Audit-Ready Documentation
  • Complete calculation trails, assumptions, adjustments, and supporting schedules.
• Risk Identification & Impact Analysis
  • Proactively identify Top-up Tax exposures and compliance risks.

Undertaking benchmarking study for arriving at the arm’s length prices for KMP payments, that involves:

• Understanding the roles and responsibilities of the KMP to the Company and determine the search strategy and search process
• Arriving at the broad comparables from database based on the nature of roles
• Detailed review of comparables and identify final comparables based on detailed review of the facts
• Arriving at an appropriate arm’s length compensation based on final comparables selected.

► Conduct searches in databases (India and Foreign) to identify appropriate comparables as that of the tax payer which involves:-

• Undertake a detailed comparability analysis using appropriate database
• Devising the search strategy and approach
• Carrying out review of brief business descriptions of companies to shortlist them for detailed review
• Undertaking detailed review of the selected companies and identification of the final list of comparable companies
• Arriving at an appropriate arm’s length results of comparable companies and provide recommendations on an appropriate transfer pricing policy

• Pillar One:
  • Analysis of applicable MNE Group on exposure of Pillar One through payment of Amount A and advisory on (re)structuring the MNE from transfer pricing perspective.
  • Evaluating option of Amount B based on detailed review of functional analysis of the distribution entities of MNE Group including applicability, evaluating restructuring & exit charge implications, robust documentation for opting under Amount B and scenario analysis.
• Pillar Two:
  • Evaluating impact of Pillar Two on the MNE Group in various jurisdictions.
  • Advisory on updating MNE Group‘s internal accounting and reporting teams to ensure accurate capturing of data points required for computing Globe ETR and filing of Globe Return.
  • Preparing the Globe Return, as prescribed in the respective jurisdictions’ tax laws.

Related party compliances arising on account of SEBI Listing Obligations, Disclosure Requirements (LODR)& Companies Act requirement.
Identification and evaluation of Related Party Transactions (RPTs) to ensure arm’s length pricing and fair valuation of such RPTs in line with SEBI-LODR requirements. Support in presentation of the same before the Audit Committee.

• Identification of related parties
• Determing whether such RPT are in the ordinary course of business;
• Determining whether the RPT are undertaken on arm’s length basis by
  • Analysing and evaluating various approvals required (i.e. audit committee, board of directors, shareholders etc.) for each of the RPT as per the Companies Act 2013 and SEBI regulations
  • Analyse other supporting documents, emails and third party information available to substantiate the pricing of the RPT
  • Review RPT compliances under the Companies Act on a quarterly/ half-yearly/annual basis and present our analysis at board meetings to assure directors that required compliances are met

Need benefit analysis documentation for intra group payments – Royalty and Management charges
Review of the documentation maintained by the company with regard to the intra-group payments and:

• Analyze whether appropriate agreements are in place with regard to the intra-group payments;
• Review of the inter-company invoices;
• Review of back-up documents maintained by the company with regard to the intra-group payments;
• Collation of evidences available with respect to intra-group payments;
  Assist in preparation of need-benefit documentation to substantiate the payment made to group entities.

Benchmarking Study for arriving at the arm’s length royalty for intangible property, that involves:

• Understanding the nature of intangible transactions – trademark or technology
• Determine the search strategy, search process and approach for undertaking the comparability analysis
• Undertake a detailed comparability analysis using the global database
  Detailed review of CUT agreements and identify final comparable agreements based on detailed review of terms of agreements
• Arriving at an appropriate arm’s length price based on the final comparable agreements.

Benchmarking Study for arriving at the arm’s length prices for interest rates using Global databases, that involves:

• Devising the search strategy and approach, based on borrower’s credit rating, loan currency and other characteristics of the loan
• Identifying the credit rating /Arriving at the credit rating of the borrower using the tools available in the Global database in cases where credit rating is unavailable
• Undertake a detailed comparability analysis using the global database to identify similar comparable agreements
• Arriving at an appropriate arm’s length result of interest rates