Transfer Pricing
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Crafting Your Roadmap to Success
Welcome to the Transfer Pricing section of our comprehensive service offerings. At HBC, we pride ourselves on assisting Indian and Multi-National Corporations develop and implement economically justifiable transfer pricing policies and documentation. Our team will work closely with them to help manage the tax impact of their domestic as well as cross-border related party transactions. Together, we will explore an effective, integrated organization wide strategy for managing many complex Transfer Pricing issues involved with inter-company transactions involving goods, services and intangibles.
We provide assistance in developing and implementing viable transfer pricing policies, harmonization of existing ones and adopting new transfer pricing structures or alignment of prices with business restructuring.
Our services broadly cover the following:
- Advisory and Consulting: At HBC, awareness regarding the laws that govern the client, his business and allied activities, is the basic and foremost step to tax advisory. We provide assistance in developing and implementing viable Transfer Pricing policies, harmonization of existing Transfer Pricing policies, adopting new transfer pricing structures or alignment of prices with business restructuring.
- Compliance and review: We assist corporation to design and implement compliance policies, and prepare robust transfer pricing documentation (TP Study). We assist with a full array of documentation services, including function, asset and risk analysis, industry overview and benchmarking analysis customized to your specific needs. We have a whole gambit of different transfer pricing databases to provide you with appropriate benchmarking analysis.
- Transfer Pricing Audits: We provide whole range of auditing services as mandated in Income tax act, 1961 with regards to transfer pricing. Our services include filling Form 3CEB and other forms related to master file and country by country reporting.
- Advance Pricing Agreements: We can assist in preparing a robust transfer pricing policy aligning with business and commercial substance along with deciding on various documents and information that need to be shared with tax authorities during the course of negotiating and implementation of APA program.
- Tax Representaion Services: Tax litigation in India requires a comprehensive approach involving people with adequate understanding of tax laws and insightful handling of contentious issues.
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Analysis
Setting benchmark price for transactions
Purchase
Sale
Royalty
Commission
Corporate Guarantee
Loan Interest
Cost Contribution
Cash Pooling, etc.
Planning
TP Policy and Strategies
Formulation and review of Transfer Pricing policies for the Group
Strategising business models and transactions to achieve management objectives.
Price setting (Benchmarking)
TP structuring - DEMPE analysis in consonance with recommended BEPS Action Plan 8-10
TP health check
TP due diligence for M&A
Drafting / review of intercompany agreements
Support in Dispute Resolution (APA and MAP)
Support
Documentation as per local laws
Assistance in maintenance of TP documentation required in accordance with laws of various countries in Europe, US, Asia Pacific, MEA, etc.
Assistance in preparation of Global Master file in accordance with recommendation of BEPS Action Plan 13
Assistance in preparation of Country by Country reporting data
Strategic TP litigation support
Assistance in certifications needed to corroborate TP methodologies - segment Profit and Loss Account, cost allocation methodologies, etc
TP Litigation
Handling TP scrutiny cases
- Preparation of Replies to notices issued by TPO and other IT Authorities
- Appearing for Personal Hearing
- Filling of appeals before CIT(A), DRP and ITAT
- Preparation of documents for filling of appeal
Why Choose HB&C for Transfer Pricing Advisory
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