Transfer Pricing

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MNEs are operating in an environment of unprecedented complexity. The rising volume and variety of intercompany transactions in the midst of a continually evolving transfer pricing solutions, accompanied by increased enforcement activities worldwide, have made transfer pricing a leading risk management issue for global businesses.

SBC, with its rich experience and demonstrated capabilities, believe in providing holistic transfer pricing solutions to clients tailored to meet business objectives and at the same time be robust, scalable, and sustainable from a BEPS & local transfer pricing regulations standpoint.

SBC provides comprehensive transfer pricing solutions encompassing – transfer pricing services for new related party transactions and transfer pricing documentation (as statutorily prescribed by local jurisdictions). We provide end-to-end litigation support across judicial forums on all Transfer Pricing matters.

We also assist MNEs in Strategizing and evaluating alternative dispute resolution routes – Advance Pricing Agreements, Transfer Pricing Audit, Mutual Agreement Procedure, Transfer Pricing Documentation, and Safe Harbour Rules. Further, with the advent of BEPS, MNEs have to ensure compliance with BEPS Actions Plans (including filing all the relevant forms relating to three-tiered documentation). SBC assists in ensuring that the information disclosed in the Country-by-Country Report, Master File, and Local File adequately factors a 360-degree view and supports the Transfer Pricing and other tax positions of the MNEs and demonstrates the compliance of the MNEs with OECD and local transfer pricing regulations.

OUR USP

SBC is a member of PrimeGlobal, a global network of 300 highly successful member firms having a presence in 100+ countries. SBC is a one-stop transfer pricing consultant firm for MNEs for regional/country comparable studies & filings.

SBC offers transfer pricing services in India through its branches and affiliates. SBC has a track of jurisdiction-wise precedents and practices.

Being Big 4 Alumni, our Transfer Pricing Audit team has direct hands-on experience in handling complex TP assignments and leverages the best practices drawn from the team’s collective experience with a view to delivering a robust transfer pricing documentation that can be defendable from a TP audit/scrutiny standpoint.

Being Big 4 Alumni, our Transfer Pricing Audit team has direct hands-on experience in handling complex TP assignments and leverages the best practices drawn from the team’s collective experience with a view to delivering a robust transfer pricing documentation that can be defendable from a TP audit/scrutiny standpoint.

Our network partners are former Tax Officers, Ex-Regulators, and Senior Counsels who share their expert opinions & views for countering aggressive regulatory positions.

OUR OFFERING

  • Transfer Pricing Compliances
  • Transfer Pricing Documentation
  • Accountant’s Report – Form No. 3CEB
  • Master File
  • Country-by-Country Report
  • Global Transfer Pricing Compliance – Regional/Country comparable studies & filings adhering to OECD guidelines and local regulations. (SBC has access to all major Indian and Global databases/software – Prowess, CapitalineTP, AceTP, Amadeus, Compustat, Kt-Mine, RoyaltyRange, RoyaltyStat, Orbis, Osiris, IBISWorld, Factiva, One Source, Loan Connector, etc.)
  • Transfer Pricing Comfort Letters/Memos for Statutory Auditors
  • FIN 48 Assistance – Quantification & Opinion on Transfer Pricing exposure and uncertain tax positions
  • Transfer Pricing analysis and Board meeting presentations for Listed Companies from SEBI Regulations and Companies Act perspective.
  • Transfer Pricing Policy & Price Setting
  • Drafting/Review of Inter-Company Agreements
  • Alternative Business and Remuneration Models that are sustainable
  • Comparable Studies and Benchmarking analyses
  • Operational Transfer Pricing
  • Group Profit & Effective Tax Planning
  • Tax efficient structuring of international transactions & transaction flows
  • Supplementary analyses to strengthen the documentation from litigation perspective
  • Voluntary Transfer Pricing Adjustments
  • Secondary Adjustments
  • Transfer Pricing Health Check-Up to avoid/mitigate risks
  • Transfer Pricing Due Diligence
  • Drawing Segmental P&L for Transfer Pricing Purposes
  • Economic adjustments computation – Risk, Working Capital, Forex, Capacity Utilisation, Depreciation, Cash PLI adjustments
  • Intangibles – Structuring, Royalty & Licencing rates, Withholding implications, Agreements
  • Financial Transactions – Interest rates, Withholding implications, Agreements
  • Intra-Group Services, Management Charges, Cost Contribution Arrangements – Charging/mark-up rates, Agreements, Cost pooling & allocation
  • Business Restructurings – Transfer Pricing implications, Agreements & Contracts review
  • General Anti Avoidance Rules (GAAR) implications
  • Permanent Establishment (PE) Exposure for existing/proposed transactions
  • First level authorities – Transfer Pricing Officers (TPO)/ Assessing Officers (AO)
  • Dispute Resolution Panel (DRP)
  • Appellate authorities – Commissioner of Income Tax (Appeals) [CIT(A)], Income Tax Appellate Tribunals (ITAT), High Court, Supreme Court
  • Penalty, Rectification, Re-assessment, Revision, Remand, Order giving effect, Stay of demand proceedings
  • Cost Benefit Analysis for decision making
  • Filing of Applications in prescribed Forms
  • Representations & Submissions
  • Application Renewals
  • APAs – both unilateral & bilateral
  • BEPS Contract Analysis
  • Value Chain Analysis and Management
  • OECD Pillar 1 & 2 – Readiness, Implementation & Impact
  • Supply Chain Restructuring
  • Three Tier Documentation support in line with Action 13
  • IP Structuring /DEMPE analysis in view of Action 8
  • Financial Transactions planning factoring in Action 4 and 9 and OECD guidelines on Financial Transactions
  • High risk transactions structuring in coherence with Action 10
  • Profit Split Method – applicability, implementation, splitting factors, projections, segmentation, planning/price setting as per BEPS
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  • Assets (tangibles & intangibles) transfer between related parties
  • Capital/financial transactions (equity, debt & hybrid instruments, guarantees) – issue, sale, buybacks between related parties
  • Mergers & Acquisitions transactions – selling, buying, combining, restructuring involving related parties
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