OTHER SERVICES

► TP comfort letters / Memo for auditors

• • • Identifying the related parties and related party transactions
    • Determining whether the RPT are at arm’s length
    • Issuance of Comfort letters/ Memo for auditors that the RPT are at arm’s length.

► FIN 48 assistance – quantification of TP exposure on uncertain tax positions

• • • Identify related party transactions
    • Understand the TP Policy
    • Determine and quantify Fin48 Transfer Pricing Exposure

► Related party compliances arising on account of SEBI Listing Obligations, Disclosure Requirements (LODR)& Companies Act requirement.

• • • 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

► Cost benefit analysis documentation for intra group payments – Royalty and Management charges

► Pillar 1 & Pillar 2 Impact Analysis

• • 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.