Transfer Pricing
Transfer pricing" refers to the transaction prices of transactions between
related parties like the parent and
subsidiary, which may take place under the conditions differing from those
taking place between independent enterprises.
The transfer price between related parties may not be at par when compared
to the transfer price on transactions with
unrelated parties.
For example, company X purchased the goods for Rs. 1000/- and sells it to
its associated company Y in another country
amounted for Rs. 2000/-, who in turn sells in the open market for Rs.
4000/-. If company X had sold it directly in the
latter country, it would have made a profit of Rs. 3000/-. But by routing it
through company Y, it restricted the profit
to Rs. 1000/-, permitting company Y to appropriate the balance. The
transactions between X and Y is arranged and are not
governed by market forces. The profit amounting to Rs. 2000/- is, thereby,
shifted to country of Y. The goods are
transferred on a price (transfer price) which is arbitrary or dictated (Rs.
2000/-), but not on the market price (Rs.
4000/-).
To protect interests of the revenue, the Income Tax Act, 1961 ("the Act")
has vide its chapter -X framed specific
provisions. The basic principle enunciated through such provisions is to be
considered "arm's length price" for the
international transactions. Almost every entity associated with an
international entity faces the issue of transfer
transfer price regulation in India. We help those entities in determining
the transfer pricing in India in the form of
providing transfer pricing reports for Indian companies within the timeframe
adopting complete legal framework.
How We are Helpful?
We are one of the best transfer pricing consultants in Pune providing complete support in preparing Transfer Pricing-TP reports in Pune.
Audit and Assurance
We are known for providing the best audit services in Pune. We provide a range of services including, but not limited, to the following:
- Transfer pricing planning and documentation assistance
- Transfer pricing study preparation and documentation
- Transfer pricing audit (Form 3CEB compliance)
- Country-by-Country Reporting (CbCR) compliance
- Representation before Transfer Pricing Officer (TPO)
-
Transfer pricing litigation
representation:
- CIT(A) [Commissioner of Income Tax (Appeals)]
- DRP (Dispute Resolution Panel)
- ITAT (Income Tax Appellate Tribunal)
Having invested a good quantum of time in the above processes and gain a rich practical experience, we can provide sound technical advice in different business and economic scenario. Solutions being provided are practical, useful and implementable. Help CFOs and Tax Managers in decision making on Transfer Prices within their Group Companies.