Transfer Pricing is one of the critical tax issues for growth-oriented businesses having international operations wherein substantial senior management’s time and attention is necessary. Irrespective of their size, organizations need an effective and dependable Transfer Pricing policy, which takes into consideration the organization’s overall business strategy and operating structure.
InCorp’s Transfer Pricing team with its rich experience and demonstrated capabilities offers comprehensive solutions in areas such as Transfer Pricing Documentation, Transfer Pricing assessments, and other value-added services such as Benchmarking services, Drafting of Inter-company agreements, etc.
Service Areas Within Transfer Pricing Services
The Transfer Pricing legislation requires that income from International Transactions between Associated Enterprises is computed after considering the arm’s length price. The term “Arm’s-length Price” refers to the price that would be charged for a similar International Transaction between unrelated third parties. The Transfer Pricing Documentation created by RSM Astute covers the various mandatory requirements under the law and includes:
- Background of the Company and its Associated Enterprises
- Functional Analysis to document the Functions, Risks and Assets deployed
- Industry Overview
- Comparability/Benchmarking analysis to prove the Arm’s Length nature of International Transactions entered into between Associated Enterprises
These services include representation before the designated Transfer Pricing Officers/Assessing Officers for Transfer Pricing related matters. The scope of services provided also covers representation before higher authorities like Commissioner of Income Tax etc.
- Planning Opportunities to achieve lower taxation for the group
- Assisting clients in Benchmarking vis a vis other players in the same industry
- Drafting of Inter-Company agreements, review of documentation etc
Frequently Asked Questions
- » Obtaining and furnishing of Accountant’s Report (Form No. 3CEB) on or before 31st October 2020 (for FY 2019-20 and onwards).
- » Maintain contemporaneous documentation in respect of transactions entered into with associated enterprises (if the aggregate transaction value exceeds INR 10 Million) giving specific details as per the prescribed rules.
- » Supplementary filings in the nature of Country-by-Country Report and Master File if the prescribed conditions are satisfied.