Transfer Pricing

As Revenue Authorities across the Globe tighten their Transfer Pricing (TP) Regulations, Multinational Enterprises (MNE's) seem increasingly vulnerable to transfer pricing adjustments that may lead to an increase in overall tax cost to the group. It is now common knowledge that Transfer Pricing is the most litigious tax issue, worldwide, resulting in protracted litigation. Tax heads of MNEs need to keep abreast of the dynamics of TP Regulations across jurisdictions in which the MNE operates to enable compliance in each such jurisdiction and adopt an appropriate risk mitigation strategy. This task becomes more challenging due to the absence of information in the public domain regarding Industry Best Practices adopted by other MNEs. PRAJCO's Transfer Pricing Practice offers end-to-end solutions by adopting a multi-disciplinary approach that includes all relevant aspects of business such as Commercial, Economic, Legal, and Tax issues. For MNEs operating in multiple Tax jurisdictions, one of the key challenges to deal with is rigorous benchmarking to justify arm's length pricing of international transactions. PRAJCO combines the economic element in pricing with information accessed from global databases to assist MNEs in this regard. MNEs need to structure the pricing of intra-group transactions that involve intangibles, services, cost contribution arrangements and financial transactions amongst other issues. In India, the scope of Advisory has widened with the TP Regulations covering even Specified Domestic Transactions. PRAJCO provides expert advice on these subjects with the backing of experience and extensive research. PRAJCO provides certification and documentation services for International and Specified Domestic Transactions. Further, it provides a comprehensive Compliance and Litigation service that includes representation before Revenue & Judicial Authorities.

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