With increase in demand on account of rising income, expanding young population base, with large pool of skilled manpower and advanced technology, India is attracting lot of multinational enterprises (MNE) leading to extensive cross border transactions. It is also a fact that various entities in the MNE group structure have given rise to transfer pricing and issues related to such transfer pricing.
Tax payers are grappling with increased Transfer pricing documentation compliances and aggressive litigation in Indian Transfer pricing arena, which requires timely and robust transfer pricing policies and documentation. The global transfer pricing policy ensures consistent transfer pricing treatment of various global transactions as per standard TP methodology, mitigating the risk of economic double taxation. Robust Transfer pricing documentation is needed to defend the tax payer against any potential risk of Transfer pricing adjustments.
Transfer pricing is generally an international tax issue but recently to bring more scientific basis in determining fair market value in related party or specified domestic transactions, Domestic transfer pricing regime has been introduced in India from Assessment year 2013-14 onwards. These domestic transfer pricing regulations have introduced the concept of arm's length pricing for such specified domestic transactions.
We provide complete life cycle support for transfer pricing process, starting from transfer pricing study including documentation, certification, assessment to litigation. We also provide advisory on transfer pricing policies and structuring services keeping in mind the widely litigative issues in India such as Intangibles and share valuations, advisory for Safe Harbour regulations, assistance in entering into Advance Pricing Agreements (APAs) and support in Mutual Agreement Procedures (MAP).