Transfer pricing is the study related to the determination of Arm Length Section92C price between Associated Enterprises Section 92A (members of the same multi-national enterprise) for the International transactions Section 92B entered into bearing effect on Profit, Loss, Income, Expenditure, Assets and Liabilities etc.
Compliance of Transfer pricing is required in the context of international or Specified Domestic Section 92BA Transaction (interstate taxation) where tax authorities are in different jurisdictions, for ensuring taxable profit is appropriately reported in each jurisdiction.
In simple words, we can say that transfer Price is the price at which transaction between two associated persons located at different jurisdiction of two countries, recorded in the books of Accounts subject to appropriately reporting of taxable profit in each jurisdiction.
TRANSFER PRICING SERVICE OFFERINGS:
- Transfer Pricing Documentation – We assist corporations to design and implement compliance policies, and prepare robust documentation.
- Transfer Pricing Planning & Supply Chain Structuring – We provide assistance in developing and implementing viable Transfer Pricing policies, harmonization of existing Transfer Pricing policies, adopting new Transfer Pricing structures or alignment of prices with business restructuring.
- Filing of audit report with the Indian tax authorities – we assist you with a full array of documentation services, including function, asset and risk analysis, industry overview, bench marking study, preparation and issuance of accountant’s report, customized to your specific needs.
- Litigation Support / Transfer Pricing Controversy Management – team will work with you to develop strategies and appropriate practices to manage athe audit/aps.peal proceeding
- FIN 48 Assistance – We provide assistance to determine and quantify your FIN 48 Transfer Pricing exposure and uncertain tax position.
- Advance Pricing Arrangements – We can assist preparing a robust Transfer Pricing policy aligning with business and commercial substance along with deciding on various documents and information that need to be shared with tax authorities during the course of negotiating and implementation of an APA program.