Transfer Pricing Services And Consultancy: Top Reasons Why You Should Choose SBC

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.

Transfer pricing is a useful strategy for allocating earnings internationally throughout the value chain, ensuring that each tax jurisdiction is compensated with a fair and equitable tax distribution. When your prices are properly planned out and established, it is simple to win the tax authority’s trust by outlining how prices were developed and how the entire price-setting process was approached.

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. This blog highlights why you should choose the expertise of Steadfast Business Consulting for your transfer pricing requirements!

Why should you choose SBC for Transfer Pricing Services?

Our Team:

Our team can provide a certain level of security for taxpayers in the event of audits, disputes, or double taxation because our experts are familiar with the risks and requirements specific to different industries. In addition, knowing that your transfer pricing reports are in compliance with industry standards gives you peace of mind.

With a robust and professional team of CAs, Corporate Consultants, Financial Consultants, and Tax Consultants, Steadfast Business Consulting is one of the best Transfer Pricing consultation companies for MNEs.

Robust Database

The firm is decked with international benchmarking databases to handle the global benchmarking work of companies spread across different jurisdictions.

Comprehensive Transfer Pricing Solutions

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 Services. We also assist MNEs to strategize and evaluate alternative dispute resolution routes – Advance Pricing Agreements, Mutual Agreement Procedure, and Safe Harbour Rules.

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.
• 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.
• In addition, 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 Advisory:

• 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
• Drawing Segmental P&L for Transfer Pricing Purposes
• Economic adjustments computation – Risk, Working Capital, Forex, Capacity Utilisation, Depreciation, Cash PLI adjustments

Planning, Implementation & Compliance support for:

• Intangibles – Structuring, Royalty & Licensing 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

Transfer Pricing Litigation support & Representations before:

• 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

Alternate Dispute Resolution Routes – Advance Pricing Agreement (APA), Mutual Agreement Procedure (MAP), Safe Harbour Rules (SHR):

• Cost-Benefit Analysis for decision making
• Filing of Applications in prescribed Forms
• Representations & Submissions
• Application Renewals
• APAs – both unilateral & bilateral

BEPS advisory – Readiness, Implementation, Impact on International Tax Structures

• 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

Valuations for arm’s length determination for Transfer Pricing purposes:

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

Conclusion

Our expertise in international transfer pricing, transaction structure, and transfer pricing compliances spans many years. We are able to illustrate and explain the ideal fusion of an international viewpoint and insights with the Indian transfer pricing laws and the actual methodology used by the Indian transfer pricing authorities.

Feel free to contact our specialists if you have any questions regarding representing your case before the transfer pricing authorities or if you would want to talk about your transfer pricing audit services to prevent litigation.