Transfer Pricing Services

Transfer Pricing compliances with ease and accuracy

Globalisation has led to the international tax framework to become applicable in every country and Transfer Pricing is one of the key concepts. Globalisation and the international tax framework has given multinational groups a unique set of challenges to face along with increasing volumes and variety of daily operational transactions. In the midst of a continually evolving global regulatory landscape as well as increased pressure from national legal entities, this situation has led to Transfer Pricing becoming a critical issue for a lot of global businesses.

Transfer Pricing is the pricing offered by one member of the multinational group to another member outside the country for exchange of goods, services and other intangibles. Transfer Pricing is a continuous task, hence businesses should apply a systematic approach for Risk Management and controls along with Compliance obligations such as documentation, records, process etc.

Our Transfer Pricing team along with tax advisors having multinational experience can be your advisor for complicated areas of International Tax. MBG Corporate Services supports you by outlining a clear Transfer Pricing strategy in line with regulatory expectations and then aligning it with your global business goals.

Our expert team can deliver vital advice on the Transfer Pricing model that resonates with your value chain through continuous financial analysis and timely interventions. We make sure to document all intercompany transactions to position your Transfer Pricing model to satisfy regulatory provisions. Our Transfer Pricing team and Tax Advisors can guide you through complicated Transfer Pricing issues and mitigate the risks of non-compliance.Following are our service offerings across the Transfer Pricing vertical:

1. Transfer Pricing Advisory and Policies

• Review of existing documentation and analysing potential impact of Transfer Pricing (TP) exposure
• Pre benchmarking study to determine suitable method, mark-up and defence files
• Advice on Value chain transformations (VCTs)/ tax-effective supply chain models
• Design and planning of related party transactions and agreements

• Analysing business models of MNEs and implement commercially efficient TP policies
• Correlate existing TP policies with transactional arrangements
• Automating TP calculations and reconciliations with customs
• Monitoring tax developments and its impact on current transactional arrangements and TP policies of the MNE group

2. Transfer Pricing Certification and Compliance

• Carrying out annual TP audit and certifications for submission with the tax authorities
• Assistance with documentation requirements to support the planning and positions adopted in TP audits

3. Dispute Resolution & Representation Services

• Handling TP assessments & representation before tax authorities
• Exploring alternative tax dispute resolution avenues i.e. before Commissioner of Income Tax (Appeals), *Dispute Resolution Mechanism and Income Tax Appellate Tribunal
  *Litigation support before Hon’ble High Courts and Hon’ble Supreme Court of India through in-house & external expert legal counsels

4. Advance Pricing Arrangements (APAs) Strategy and Filings

• Develop strategies for unilateral & bilateral APAs and filing applications for obtaining tax certainity

5. Base Erosion and Profit Shifting (BEPS) Compliance

• Assistance in preparation of three tier TP documentation including Country-by-Country Reporting (CbCR)
• Analyzing MNE blue print through Master File (MF) prepared by the group and filing of MF with the tax authorities
• Collation of tax jurisdiction wise details and consolidation into group level for filing CbCR with the tax authorities
• Analysing legal v/s beneficial ownership of intangibles