Transfer Pricing

While optimising the Transfer Pricing related work, we help you planning today for your future transactions with a goal of reducing tax liability, mitigating foreign exchange risk, better competitive advantage and thus, maximize profits.

We have what you need:

Transfer Pricing is essential when Multinational corporations situated in India conduct business with their related parties outside India or vice versa. Our firm has an expertise while working for years towards minimising TP risk and our Transfer Pricing professionals can help you with following services:

 TP structure and planning on end to end basis 
 TP documentation (Master file and local file)
 TP compliance requirements at domestic and international level
 International Taxation planning
 Setting, analysing and reviewing Transfer Prices at transactional level
 Benchmarking studies
 Country by country reporting (CbCR)
 TP due diligence
 Advance pricing Agreements (APAs) – agreement between Tax payer and Tax authority determining TP methodology
 Audit defense services
 Steer through TP audits, disputes and appeals
 TP Training, policy formation and implementation

Transfer Pricing

Introduction:

What Is Transfer Pricing?

Transfer Pricing is explained under section 92A-F of Income Tax Act supported by rules 10A-E of Income Tax Rules 1962. Basically, Transfer Pricing is a price of transaction between related parties or associated enterprises or between unrelated enterprises but controlled by common entity that is most likely the cases of Multinational companies operating worldwide. Thus, TP is a price of goods or services or technology exchanged or traded between two related enterprises and the said price may differ from price of transaction taking place between unrelated enterprises. An example of TP is explained below for further clarification.

Suppose a company A purchases goods for 100 rupees and sells it to its associated company B in another country for 200 rupees, who in turn sells in the open market for 400 rupees. Had A sold it direct, it would have made a profit of 300 rupees. But by routing it through B, it restricted it to 100 rupees, permitting B to appropriate the balance. The transaction between A and B is arranged and not governed by market forces. The profit of 200 rupees is, thereby, shifted to the country of B. The goods are transferred on a price (transfer price) which is arbitrary or dictated (200 hundred rupees), but not on the market price (400 rupees). Concept of Transfer Pricing introduced with a motive to ensure the parity in price of transactions happening between related parties and price of transactions happening between unrelated parties to keep such prices comparable.

Learn About Our Transfer Pricing Services:

Mostly Multinational Companies use Transfer Pricing to establish the arm’s length prices for Related Party transactions across borders. Therefore, Tax Authorities throughout the world are of this opinion that Multinational Companies are trying to erode their tax liabilities by using manipulative TP arrangements and due to which, Tax authorities are aggressively conducting or tend to conduct audits of corporate to ensure compliance with Transfer Pricing guidelines and prevent Tax erosion.

JILIAN can help you to choose the best Transfer Pricing method resulting in minimizing risk and maximizing profits while keeping an organisation within the limits of TP guidelines and also to have ideal Tax structure in place. By having a worldwide presence, JILIAN is an expert unit of highly experienced and qualified Chartered Accountants, Tax Practitioners, lawyers, Company Secretaries, MBAs and other supporting staff which are successfully assisting our clients by customising Transfer Pricing structure as per their needs.

Our Transfer Pricing professionals can help in following ways basis your business needs:

 Advising on transaction structures and choosing transfer pricing methods
 Formulation of international tax plan to meet business objectives;
 Determining transaction prices for permanent establishments including Project Offices, Liaison offices and Branches;
 Implementation of TP policies;
 Coordination with government agencies and Tax Authorities
 Advise organisations on TP Audit and Assistance on end to end basis.
 TP Risk assessment and providing best possible solutions

And, amidst the Covid-19 pandemic, JILIAN has an efficient business continuity plan in place along with keeping in mind our ginormous responsibility of safe guarding the health of our employees and ofcourse, our clients and therefore, ensure to keep our client service process hassle-free and flexible.