Transfer Pricing Assessment

It includes services related to guidance and representation before government authorities in respect of audit/assessment of transfer pricing transactions. The audit of transfer pricing by government authorities refers to the examination and scrutiny conducted by tax authorities to assess the compliance of multinational companies with transfer pricing regulations. Our services include:

• Analysis of audit examination and information request
• Interviews of assessee and discussions
• Adjustment proposal and representation
• Legal research and analysis of transactions

Transfer Pricing Study

Transfer pricing study services assist multinational companies in establishing and documenting the appropriateness of their transfer pricing arrangements to comply with local regulations and international guidelines. These services encompass the following key aspects:

• Functional and risk analysis
• Comparable analysis
• Transfer pricing method selection
• Data collection and document preparation
• Economic analysis, risk assessment and mitigation

Filing of Master File and Local File

These services aim to help multinational companies meet their transfer pricing documentation obligations by preparing comprehensive master files and local files. By engaging in proper data collection, analysis, and documentation preparation, companies can demonstrate compliance with transfer pricing regulations, enhance transparency, mitigate transfer pricing risks, and support the arm's length nature of their intercompany transactions.

• Information gathering and document preparation
• Transfer pricing analysis
• Assessment design as per local laws
• Integration between master file and local file
• Filing of local and master file as per the regulations

Country-by-Country-reporting (Cbcr) analysis

CBCR analysis refers to the examination and assessment of Country-by-Country Reports (CBCRs) prepared by multinational companies as part of their transfer pricing documentation obligations.

CBCR analysis is crucial for multinational companies to ensure compliance with CBCR reporting requirements and to manage transfer pricing risks effectively. By conducting a comprehensive analysis of the CBCR data, companies can identify potential transfer pricing issues, implement proactive strategies, and enhance transparency in their global allocation of income and taxes.

Dispute Resolution Panel (DRP) Proceedings

Dispute Resolution Panel (DRP) proceedings refer to the alternative dispute resolution mechanism available to taxpayers in relation to transfer pricing and international tax disputes. Our services include:

• Representation before the Dispute resolution panel
• Collection of Data and analysis
• Legal research and evaluation of the case
• Analysis of the eligibility and option of filing of appeal
• Implication of DRP decision