The term Transfer Pricing refers to inter-company pricing arrangements between related business entities and commonly applies to inter-company transfers of services and tangible / intangible properties. An appropriate transfer pricing policy is one of the most important international tax tools in international business. With increase in cross border investments and due to global integration, transfer pricing assumes greater significance today. Stringent penalties, comprehensive contemporaneous documentation requirements and increased information exchange among different jurisdictions have made it absolutely imperative for corporate houses to find innovative transfer pricing solutions. For several Indian companies this is a new development, as transfer pricing regulations have been recently made mandatory in India with regard to any Indian company that has an international transaction with an associated enterprise. Given the fact that several other countries also have similar transfer pricing regulations, although with subtle differences, it is imperative that the pricing policy in India and abroad is properly coordinated.

We have considerable experience and expertise in transfer pricing matters and the broad scope of services that we could provide, in co-ordination with our UK/US associates, if required, include:

• Developing appropriate methodology to identify various transfer pricing issues
• Analysing tax implications under relevant double tax avoidance agreements
• Undertaking tax planning (for IT/ITES companies and for other exporting units), in terms of maximizing s.10A / s.10B benefits and minimizing the overall tax exposure for the Group at large
• Alignment of transfer pricing with client’s global business goals and objectives
• Formulating and assisting in implementing an optimal transfer pricing policy, considering not just the transfer pricing issues but also withholding tax, international tax, exchange control aspects and STPI issues
• Developing the transfer pricing strategy not only with a view to meet the Indian transfer pricing requirement but also with a view to satisfy the tax authorities of the overseas jurisdiction
• Assisting in maintenance of desired level of documentation in support of transfer pricing policy formulated
• Providing tax compliance and representation services and defending the transfer pricing policy in the event the case is picked up for audit by tax authorities

• Is practical to implement
• Will stand up to the scrutiny of tax authorities and
• Will minimize the risk of being saddled with tax adjustments and / or penalties at the time of audit.

• We have dedicated transfer pricing specialists with training in and exposure to international accounting, international tax, law and economies
• We have associates in the UK and the US, who have provided their assistance on transfer pricing to many of the Fortune 500 companies. Our associates have immense transfer pricing expertise and are well recognized by America’s business leaders and tax authorities across the globe
• We have been specifically trained on transfer pricing in the US and the UK. We have also undergone a correspondence course on transfer pricing with International Monetary Forum (IMF)
• We have been appointed by the Gem and Jewellery Export Promotion Council of India to study the applicability of the Indian transfer pricing regulations to the Gem, Jewellery and the Diamond industry and thereafter make a representation to the Government
• We have access to Indian and overseas transfer pricing databases for running searches for comparable transactions
• Although our overseas associates may be involved in formulating a transfer pricing policy with a view to balance it from the Indian and the overseas side, we act as a single point of contact for our clients.