Transferring Pricing
ENERGY PROGRESS
What is Transfer Pricing?
Transfer Pricing is a regulatory mechanism for transactions between group entities of a multi-national corporations having its footprints across various countries. It is a complex matter and can significantly affect the tax liability of a company on which it applies. Every country is concerned about its tax revenue, which in turn depends upon the profitability of the organizations having business in that country. Related transactions between such group entities can be a key determinant calculating their profitability and thus, every government keeps a strict check upon such transactions for assuring their fidelity.
Transfer Pricing involves determination of arm’s length price for such related transactions through a detailed analysis and study of similar transactions in the industry. Transfer Pricing provisions are humongous and requires services of experts, like Aplite, for annual return and report filing.
Our Services
Transfer Pricing is a wide sea and involves numerous compliances and is highly susceptible to controversies and litigations. Thus, Aplite extends its following services:
1. Advisory: Our advisory services include structuring international transactions, suggestions for arm’s length price and detailed industry analysis, formulation and implementation of global transfer pricing strategies, functional analysis and measures for mitigation of transfer pricing risks.
We provide end-to-end services, right from the start till the end. For every international transaction of yours, we will help you determine its scope, related regulatory risks and advice you upon how to effectively structure them for full optimisation.
2. Documentation & Compliances: Transfer Pricing involves maintenance of extensive documentations and compliance with regulations. Aplite has always been helping its clients in meeting their regulatory needs. Let us glance through these:
• Preparation of detailed transfer pricing documentation relating to international and specified domestic transactions as required under Section 92D of Indian Income Tax Act, 1961.
• Issuance of Accountant’s Report / Transfer Pricing Certification (Form 3CEB) as required under Section 92E and related Rules.
• Assistance in Preparation and submission of Master File and Country by Country reports (CbCR) in accordance with OECD’s BEPS Action Plan.
3. Advance Pricing Agreement (APA): It is an agreement between the taxpayer and Tax Department of India wherein the method of determination of arm’s length price for an international transaction is pre-agreed to avoid future confusions and to & fro. It is not always easy to enter into APA as settling upon common terms with the Department is time-consuming and requires a detailed back study and calculations.
Aplite has a rich experience in securing successful advance pricing agreements for its clients. Such agreements remove future uncertainty and boosts confidence. We handle everything from drafting agreements to coming to common terms with department. APAs are sure-shot method of avoiding international litigations.
4. Transfer Pricing Litigations: As already discussed, transfer pricing is highly subject to litigations and disputes since the stakes involved are generally very high and there is no one best method for determinations of arm’s length price.
Under our litigation services, we handle everything from drafting replies to representation before various authorities like Transfer Pricing Officer (TPO), Commissioner of Income Tax (Appeals), Dispute Resolution Panel (DRP) and Income Tax Appellate Tribunal (ITAT). We also assist in application of Safe Harbour Rules and Mutual Agreement Procedure (MAP).
Why Choose Aplite?
Aplite is a leading financial and taxation service provider in India with more than 10 years of rich testimonials and successful stories. There cannot be even one reason to not to choose Aplite. Aplite offers following competitive advantage to its clients over others:
1. We have a team of highly specialised, experienced Chartered Accountants who are experts in their subject matter fields and are fully aware of the nitty-gritties of their fields. It is always a pleasure to be in touch and avail services from such experts.
2. We have PAN India presence and thus, offer one-stop solution for all organisations having operations at multiple locations.
3. We offer wide variety of services. Thus, you do not need to consult different experts for your varied needs.