Transfer pricing refers to the pricing of goods, services or intangibles with a multinational organization particularly in regard to cross-border transactions.

Multinational organizations in the recent times are operating in an environment of unprecedented complexity. As global trade increases, companies are confronted with complex issues associated with inter-company pricing, accompanied by increased enforcement activities worldwide which have made transfer pricing a leading risk management issue for global businesses.

Our team of experienced Transfer Pricing professionals have in-depth knowledge of the tax and statutory requirements and a breadth of experience applying such knowledge in practice. With a team supported by international tax experts and business advisors, we assist in planning, streamlining, managing, and solving complex transfer pricing issues to mitigate transfer pricing risk and aligning it with the client’s global business operations and objectives.

Our service offerings:

TP Planning and Advisory

• Strategic advice in reviewing the remuneration model that aligns with the value chain of the group and providing implementation support
• Support in review of inter-company agreements
• TP analysis and advice on complex inter-company transactions including intangibles, management fee, inter-company financing
• Assistance in undertaking due diligence assignments from a transfer pricing perspective in respect of target acquisition

TP compliance

• Preparation of transfer pricing compliance documentation for international transactions and specified domestic transactions
• Issuance of Accountant’s Report in Form 3CEB
• Assistance in preparation of Master File and Country by country (CbCR) and related compliances

Dispute Management

• Tax litigation support before transfer pricing authorities and handling legal proceedings
• Tax briefings and providing external support to external counsels for representations before High Court and Supreme Court
• Assistance with advance pricing agreements (APA) and gaining tax certainty
• Assistance with Safe Harbor application
• Assistance with mutual agreement procedures (MAP)