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Provider of business communication applications based on IP technologies

  • Task at hand
    • Conducting a benchmarking analysis for a captive contract R&D unit and preparing the tax planning transfer pricing study report.
 
  • Challenges faced
    • Appropriate classification of the R&D services in line with CBDT Guidelines;
    • Lack of comparable companies in the software industry with financial data available in public domain; &
    • Justifying the use of broad range of comparable companies providing R&D services in pharma industry.
 
  • Outcome/value provided
    • Prepared transfer pricing documentation and discussing the margins;
    • Provided inter-company contracts and held discussions for implementing the transfer pricing margins; &
    • Developing an invoicing and transactional flow.
 
  • Client feedback on the project
    • Client discussed and accepted the analysis. The report was also accepted by the R&D center authorities.