Transfer Pricing Anchor – a co-management framework

Accretive SDU’s approach to transfer pricing decisions involves a review from a multi-disciplinary perspective covering management control, economics, legal, tax, finance and cost accounting. Our offerings encompass:
Design of transfer pricing system

• Designing of alternative models from a transfer pricing and tax optimization perspective

Evaluation of alternative models

• Review of alternative business and pricing models from a direct and indirect tax perspective
• Assist management in selection of the model, best aligned to the business

Implementation

• Drafting/review of inter-company agreements
• Drafting pricing policy for intra-group transactions
• Determination of arm’s length price or costing model for intra-group transactions through benchmarking analysis and valuation exercises
• Assisting in preparation of Transfer Pricing Documentation folder in accordance with respective country’s regulations
• Integration of transfer pricing policies with financial recording systems

Guidance

• Providing routine clarifications on regulations and implementation
• Participating in Transfer Pricing compliant decision makings of company

Compliance Assistance

• Periodic review of international transactions to ensure compliance with the arm’s length standard and ensure contemporaneous documentation
• Assisting in periodic compliances i.e., Annual Transfer Pricing Documentation to be maintained by the Company;
• Assisting in compliance filings with tax office and litigation

Transfer Pricing Representation Services
Transfer pricing audit

• Representation assistance during hearings with the income tax authorities

Dispute Resolutions / Appeal before the Commissioner (Appeals) / Income-tax Appellate Tribunal

• Preparation of the submissions and representation assistance before the Dispute Resolution Panel or Commissioner (Appeals) or the ITAT

High Court and Supreme Court

• Working with lawyers as a subject matter expert

Advance Pricing Arrangement

• Assisting in organizing relevant documentation for the application to be filed with the Competent Authority under the prescribed regulations

Mutual Agreement Procedure

• Assist in drafting and presenting application to Competent Authority for mutual agreement procedure (MAP) under the tax treaties