TRANSFER PRICING ADVISORY

► Designing Global Transfer pricing Policy

• • Evaluate the business and identify the value drivers in the supply chain
  • Identify the characterization of entities (in accordance with the functions performed, risks assumed and assets utilized) and selection of tested party for the analysis.
  • Evaluate the most appropriate transfer pricing method as prescribed for the international transaction as per the applicable Transfer Pricing Regulations.
  • Price setting through benchmarking
  • Evaluate the cost covered for invoicing with respect to all transacting entities in the proposed structure
  • Provide guidance as to the internal documentation that may need to be maintained by the company from transfer pricing regulations perspective
  • Support to draft the global TP policy

► Drafting Intercompany agreements

• • Drafting intercompany agreements from a transfer pricing perspective on various clauses and aspects, based on understanding of the business activities undertaken by the Company and its Group entities.

► Transaction Structuring

• • Evaluate the supply chain to identify the value contributions of various entities and the transaction flows across jurisdictions
  • Support to ensure compliance with the OECD BEPS action plans in conenction with various inter group transctions (tangible, intangible, financing, services)
  • Support to evaluate any implications on account of business model conversions including exit charge implications in various jurisdictions