TRANSFER PRICING

Are you seeking assistance in the identification, assessment, and adoption of practices that are in congruence with transfer pricing rules and regulations?

 

KNAV’s transfer pricing practice can assist your company maximize tax efficiency and at the same time minimize the risk of tax adjustments and penalties.

 

Our services include –

 

TRANSFER PRICING DOCUMENTATION

International trade is increasing every year, but did you know that a third of all the world’s trade consists of intercompany transactions? This is a huge amount of global trade traffic and that is why transfer pricing has become a critical aspect for multinational corporations (MNCs).

KNAV’s transfer pricing practice can assist your company maximize tax efficiency and at the same time minimize the risk of tax adjustments and penalties.

 

Some of the key areas we assist clients includes:

 

  • Preparing tailor–made transfer pricing documentation that ensures a consistent application of local transfer pricing rules and regulations across jurisdictions.
  • Preparing of BEPS aligned global/regional/country specific master file and conducting gap analysis with the group’s master file.

Preparing County by Country Report (CbCR) as per the regulations of the jurisdiction where the reporting entity is incorporated.

 

BENCHMARKING ANALYSIS

Given the operating environment, you want clear direction and understanding of the transfer pricing for your company’s intercompany transactions so that you can better budget and manage profitability.

To achieve that goal, we’ll work with you, applying KNAV’s transfer pricing benchmark analysis. Even if you conduct transfer pricing studies inhouse, you will appreciate our assistance with benchmarking update on annual basis. Our global transfer pricing team assists the corporations with this exercise using various global and local databases that are acceptable to the local tax authorities in the respective countries.

 

This becomes the cost-efficient solution for such corporations firstly because they do not need to invest in expensive databases and secondly are able to outsource the tedious benchmarking exercise.

 

RISK ASSESSMENT, PLANNING & ADVISORY

We analyze transfer pricing exposures, identify opportunities, and advise on the best strategies by blending our technical tax expertise with a thorough understanding of your business.

 

Some of the key areas we assist clients includes:

 

  • Restructuring operations keeping in mind the local tax laws as well as the Double Tax Avoidance Agreements between countries.
  • Review of existing business model and suggesting alternatives and its implications on over all supply chain from a transfer pricing perspective.
  • Assisting in designing comprehensive global planning solutions, including supply chain, cash repatriation, and international expansion.
  • Assisting in transfer pricing due diligence analysis and highlighting potential risk exposures.
  • Integrating transfer pricing after mergers, acquisitions, business changes.
  • Assisting in preparation of uncertain tax position (ASC 740-10) documentation under US GAAP for transfer pricing positions.

 

DISPUTE RESOLUTION & LITIGATION SUPPORT

We will defend your transfer pricing policies before tax authorities for various inter-company transactions. Some of our key services includes:

 

Some of the key areas we assist clients includes:

 

  • Assisting in representation before various tax authorities to defend the transfer pricing policy adopted and documented by the MNCs
  • Developing defensible positions and cogent arguments, founded not only in transfer pricing principles, but also in consideration of the commercial decisions that have been made historically, the industry practices and legal restrictions or regulations that are in place at the time.
  • Identifying and gathering the relevant evidence that is crucial in supporting claims and statements made
  • Assisting in compilation and filing of submissions/ information/documents as requested by the tax authorities
  • Advising and assisting in preparation and filing of Advance Pricing Agreement and Mutual Agreement Procedures before revenue authorities to avoid double taxation or at least achieve better tax efficiency