The Indian transfer pricing regulations requires the pricing of any international transactions between related parties to be at arm’s length and needs to be justified using the prescribed methods.

Transfer pricing requires a strong understanding of the facts of the company as well as the industry in order to determine the appropriate arms’ length price. Since these are fact driven, there are generally disputed by the tax authorities at lower level if the same are not adequately captured in the documentation. Transfer pricing is one of the most challenging tax issues in India and across the world and has a key influence on a company’s worldwide tax burden. Further, with action plans and amendment in the local laws and treaty to address the Base Erosion and Profit Shifting (BEPS) and General Anti Avoidance Provisions, maintaining of robust documentation & have the substance in place becomes very crucial for the corporate to defend its arm’s length test.

We assist clients in determining the arm’s length price, maintaining documentation to support the price adopted by the company before the tax authorities, providing planning opportunities at a group level. We also help clients in determining the right supply chain model or business model to optimize the effective tax rate at the Group level.