Details

At VIPUL PATIL & ASSOCIATES, we specialize in providing comprehensive Transfer Pricing services to businesses engaged in cross-border transactions with their associated enterprises. With increasing scrutiny from tax authorities and stringent compliance requirements, businesses must ensure that their international transactions adhere to Arm’s Length Pricing (ALP) and comply with India’s Transfer Pricing Regulations under the Income Tax Act, 1961.

Our Transfer Pricing Services

1. Transfer Pricing Advisory & Tax Planning

We help businesses develop effective tax strategies to optimize their transfer pricing structures while ensuring compliance with Indian and international tax laws. Our expert advisory services include:

• Analysis of inter-company transactions and pricing mechanisms.

• Identifying potential tax risks and structuring transactions to mitigate them.

• Guidance on inter-company agreements and policies.

• Advice on aligning transfer pricing policies with global best practices.

2. Calculation of Arm’s Length Pricing (ALP)

The Arm’s Length Principle ensures that the pricing of inter-company transactions is consistent with market rates. We assist in:

• Selecting the most appropriate transfer pricing method (Comparable Uncontrolled Price, Resale Price, Cost Plus, Profit Split, or Transactional Net Margin Method).

• Conducting benchmarking studies using industry databases.

• Evaluating financial data of comparable companies for price determination.

• Determining an accurate Arm’s Length Price for transactions such as goods, services, intellectual property, loans, and royalty payments.

3. Transfer Pricing Documentation & Compliance

Maintaining proper documentation is crucial for justifying transfer pricing policies and avoiding penalties. We provide end-to-end assistance in:

• Preparing Master File and Local File documentation as per Rule 10D of the Income Tax Rules.

• Conducting functional, economic, and risk analysis of related-party transactions.

• Preparing detailed reports to substantiate transfer pricing policies.

• Ensuring compliance with statutory disclosure requirements in tax returns.

4. Transfer Pricing Certification (Form 3CEB)

Companies engaging in international transactions or specified domestic transactions exceeding prescribed limits are required to obtain a Transfer Pricing Certificate (Form 3CEB) from a Chartered Accountant. We assist in:

• Reviewing inter-company transactions for compliance.

• Issuing Form 3CEB certification.

• Liaising with auditors and tax authorities for accurate reporting.

5. Transfer Pricing Dispute Resolution & Litigation Support

In case of transfer pricing audits or disputes with tax authorities, we offer expert representation and litigation support, including:

• Handling tax assessments and audits related to transfer pricing.

• Filing appeals before the Dispute Resolution Panel (DRP), Income Tax Appellate Tribunal (ITAT), and other appellate authorities.

• Negotiating Advance Pricing Agreements (APA) to avoid future disputes.

6. Global Transfer Pricing Compliance

For multinational companies operating in multiple jurisdictions, we assist in global transfer pricing compliance by:

• Aligning local transfer pricing policies with OECD guidelines and BEPS (Base Erosion and Profit Shifting) regulations.

• Ensuring consistency in inter-company pricing across different tax jurisdictions.

• Assisting with country-by-country reporting (CbCR).