We help clients execute industry-specific taxation strategies that allow them to realize exceptional business value.
Steadfast Business Consulting serves clients across various verticals as they navigate an increasingly complex tax landscape under both national and international guidelines.

Our tax professionals can help solve your tax challenges, offering in-depth, up-to-date knowledge of the relevant local rules and regulations and helping you keep up with the ever-changing regulations.

The evolution of the taxation framework has become very complex. This is majorly due to an increase in cross-border business models.
Managing such complexity has become necessary for enterprises to maximize value from every important business decision.
SBC ensures that you maintain compliance, and we also make sure that we create value for your business, giving you the best tax advice & assistance.

TRANSFER PRICING

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GOODS AND SERVICES TAX

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INCOME TAX

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TRANSFER PRICING

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 regulatory landscape, 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 planning 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 Strategize and evaluate alternative dispute resolution routes – Advance Pricing Agreements, Mutual Agreement Procedure, 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 presence in 100+ countries. SBC is a one stop transfer pricing consultant for MNEs for regional/country comparable studies & filings.

SBC has presence across India through its branches and affiliates. SBC has a track of jurisdiction wise precedents and practices.

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

Apart from Indian databases, SBC is equipped with global benchmarking databases thereby having capabilities of handling end to end global benchmarking exercises of MNE groups spread across various jurisdictions

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

OUR OFFERING

  • 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/softwares - 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

    • Assets (tangibles & intangibles) transfer between relation 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

    GOODS AND SERVICES TAX

    GST is a transaction tax that has subsumed most of the legacy indirect taxes levied by the Centre and States. Given the magnitude of the change, it comes with its own set of implementation challenges and complexities. Businesses have re-visited their tax structures and have realigned to same match the business requirement under GST. As the law is comparatively new, regular amendments circulars are being issued by CBIC.

    Our subject matter experience in Indirect Taxation and experience in handling GST transition for various businesses puts us in an ideal position to ensure compliance with GST law and in provision in provision of value-driven services to our clients.

    OUR OFFERINGS

    Doing things not just right, but also at the right time is very essential in adhering to tax compliances. Our gamut of services under Tax compliances include:

  • Computation of tax payments and filing of various returns
  • Assist in reconciliation of input tax credits as per the GST system and as appearing in records maintained by the Company
  • Preparation of compliance tracker
  • Assist in queries related to e-Way bills generation
  • Assistance in undertaking GST Annual compliances
  • With the objective that the taxes are not exported or embedded in the supply chain, refund of GST paid on eligible purchases is extended as refund to exporters and businesses covered under inverted duty structure (i.e., instances where the rate of tax paid on input is higher than the rate of tax payable on outward supplies made). We at SBC, have in-depth knowledge of the intricacies in different refund options, undertake cost-benefit analysis and suggest best workable options in client specific facts including the following:

  • Evaluating the alternatives of refund/rebates and advising on the beneficial method for claim
  • Designing system for generation of necessary documentation for preparing refund claim
  • Assistance in retrieval of supporting documents
  • Preparing refund claim as per statutory requirement
  • Filing refund claim with department and making follow up
  • Making representation in case refund claim rejected
  • GST is still in nascent stages and evolving both from a policy and implementation perspective there are several uncertainties in interpretation of the provisions. With the possibility of multiple interpretations being taken, several issues resulted in an increased litigation. We at SBC with our experience in handling such issues would be glad to assist our clients in:

  • Preparing replies to various notices, drafting appeals, etc.
  • Drafting and filing applications seeking advance rulings
  • Representation services
  • Litigation review exercise to formulate strategy for swift resolution of matters
  • We shall undertake to review the overall tax positions and compliances undertaken by the Company, thereafter, suitably advising for any tax efficiencies. The review is intended to unearth any possible gaps in the tax system adopted. With our experience, we know the possible areas where there can be lapse in the tax system implemented. As a part of review, we shall:

  • Review as-is position of the Company as to whether the same is in consonance with the existing GST provisions
  • Identify risks and opportunities viz. areas of non-compliance and potential tax exposures, areas of savings, etc. and providing suggestions on the same
  • Review of various processes followed by Company from GST perspective
  • The Foreign Trade Policy has been issued by the Ministry of Commerce to promote and facilitate exports of goods out of India and to also govern imports into the country. Amongst others, the Policy provides for

  • Setting-up unit as a STP/EOU
  • Remission of Duties and Taxes on Exported Products (RoDTEP)
  • Rebate of State & Central Taxes and Levies Scheme (RoSCTL)
  • Service Exports from India Scheme (SEIS)
  • Merchandise Exports from India Scheme (MEIS)
  • Import of goods under Advance Authorisation/ EPCG scheme
  • Star House Exporters recognition
  • We at SBC, have consistently assisted our clients in optimising the claim of different incentives extended under the FTP

    INCOME TAX

    Our goal at Steadfast Business Consulting is to minimize your business and personal tax exposure by means of legitimate planning and keeping you aware of the changing requirements of the taxation system in India and abroad. We offer a plethora of fully integrated direct tax and regulatory services for dynamic businesses in their global operations as well as local operations.

    As the ease of doing business in India is increasing, investors are enthusiastic about making investments in the country. Our specialist teams provide the most tax-effective solutions to large multinational companies, mid-size businesses, high-net-worth individuals, and entrepreneurs looking to grow their businesses.

    OUR OFFERINGS

    Tax Planning plays a pivotal role in every business - whether it is a start-up or a global MNC. With dynamic changes taking place in the Indian Tax system, it is essential for businesses to adopt / adhere to effective Tax planning strategies which play hand in hand to achieve its goals & objectives. Key Tax Planning & Advisory services we offer include:

  • Tax Due Diligences & Health check
  • Place of Effective Management (POEM) & Significant Economic Presence (SEP)
  • General Anti-Avoidance Rules (GAAR) & Base Erosion and Profit Shifting (BEPS)
  • WHT advisory on domestic & international transactions
  • Entity Restructuring to achieve optimal effective tax rate
  • ICDS: Impact analysis & implementation
  • On one hand, with the introduction of Faceless Tax Litigation, the Indian Tax Administration is moving towards a more transparent & technology oriented judicial system; whilst on the other hand the ever-changing tax laws pose a lot of interpretational issues along with certain administrative challenges as well. Our key services under Tax Litigation & Controversy include:

  • Faceless Assessment & Appeals Representation (including CIT-A, Tribunal, High Court & Supreme Court)
  • Advance Rulings (new Board for Advance Rulings) & MAP (Mutual Agreement Procedure)
  • NIL / Lower WHT Certificates (Domestic & International transactions)
  • Tax Scrutiny Preparedness (Maintaining effective tax documentation)
  • Doing things not just right, but also at the right time is very essential in adhering to tax compliances. Our gamut of services under Tax compliances include:

  • Filing of Tax Returns (Corporate, Individual, Trust, Resident / NR, etc)
  • WHT Compliances
  • Managing Group Tax compliances under single dashboard
  • Miscellaneous compliances viz., Advance Tax, TCS, Equalisation Levy
  • Over the past decade, India has evolved by leaps and bounds in the digital landscape. This has led businesses across the world to interact and expand global business opportunities. With such globalisation, due care has to be taken not only with respect to Indian Tax matters, but global tax aspects as well. Our services under Cross-border taxation include:

  • Advisory on WHT applicability for various international transactions
  • Global Entity Structuring / Restructuring
  • Permanent Establishment (PE) implications
  • BEPS & POEM impact along with GAAR implications
  • Due to the increase in global footprint by Indian firms and MNCs present in India, the number of Expat workforce has increased substantially in the recent past. Our services towards Expats include:

  • Compensation structuring
  • Social Security advisory & compliances
  • Filing of Tax Returns (in India & outside India)
  • Tax Litigation support in India
  • In addition to the above, certain Individuals viz., HNIs, Venture Capitalists, CXOs, etc., may require specific tax/succession planning services as follows:

  • Family Trust set up & maintenance
  • Office Management services
  • Wealth management advisory