Transfer Pricing

With the current phase of rapid globalization and India becoming a preferred destination for INVESTMENT, number of multinational Companies (SMEs, middle size and large size corporate) are intending to invest in India OR expand their operations for number of reasons in India. This leads to possibility of various international transactions between similar group / similar management companies, which are technically called as Associated Enterprises (AEs). Generally, corporate is required to have consultancy services for transfer pricing when there are international transactions between AEs to ensure that said international transaction was entered into at Arm’s Length Principle. Examples of such international transactions are:

1. Proprietary materials shipped from one country to other country,

2. Finished products shipped from one country to other country,

3. Management Fees for involvement of key management people from one company to other company

4. Royalty / Technical Fees payment

5. Capital Goods shipped from one country to other country etc.

Transfer pricing is gaining popularity across the globe to ensure that correct transaction value (As per Arm’s Length Principle) have been booked in the originating country and destination country. Generally, OECD guidelines clubbed with local laws of the country are driving force for such study. Professionals have not only to be updated with the latest development on transfer pricing but also to be resourceful for having global data base. Professionals also have to be rich in experience in the subject as Transfer Pricing is not a science but an art or judgement.

We provide under mentioned consultancy in Transfer Pricing: Identification and evaluation of Permanent Establishment exposure Identification and preparation of memorandum of potential international transactions which could be subject to transfer pricing study Benchmarking study from the transfer pricing guidelines perspective for the subject international transaction

Issuing an opinion report

Drafting agreement / document, depending upon nature of international transactions Customize check list of documentation

Transfer Pricing Transaction Verification Audit

Transfer Pricing statutory audit