With the advent of globalization the opportunity to become global leaders is driving more and more entities out of their home countries to tap available opportunities to reduce costs and gain market shares. Applicable foreign exchange and tax laws in different territories require proper due diligence to be done before expansion of operations. Whether you are an Indian company looking to expand overseas or a foreign company wanting to invest in India, you must understand the laws that can affect your business strategy and operations.
With increase in increased globalization India is attracting many multinational enterprises (MNE) leading to extensive cross border transactions. It is also a fact that various entities in the MNE group structure have given rise to transfer pricing and issues related to such transfer pricing.
Consequently tax payers are required to comply with increased Transfer pricing documentation compliances and aggressive tax litigation in Indian Transfer pricing arena, which requires timely and robust transfer pricing policies and documentation. The global transfer pricing policy ensures consistent transfer pricing treatment of various global transactions as per standard transfer pricing methodology thereby mitigating the risk of economic double taxation.
Transfer pricing is generally considered an international tax issue. However in order to bring more scientific basis in determining fair market value in related party or specified domestic transactions, Domestic transfer pricing regime has also been introduced in India. These domestic transfer pricing regulations have introduced the concept of arm's length pricing for such specified domestic transactions.
We provide life cycle support for transfer pricing process, starting from transfer pricing study including documentation, certification, assessment to litigation. We also provide advisory on transfer pricing policies and structuring services keeping in mind the widely litigated issues in India such as Intangibles and share valuations, advisory for Safe Harbour regulations, assistance in entering into Advance Pricing Agreements (APAs) and support in Mutual Agreement Procedures (MAP).