The firm has formulated the transfer pricing policy for multinational enterprises including the pricing policy and documentation. The firm’s client in this area include
An Indian headquartered company engaged in manufacture and distribution of medical equipment and re-agents had subsidiaries and manufacturing facilities in several countries in Europe and US with complex structure of transactions between these companies. The firm helped the group to formulate world-wide transfer pricing policy considering the tax laws of different countries. The scope also included requirement of maintaining documentation for each of the countries as per their local legislation. The firm also provided support for enabling the group not only to formulate policy but also determine specific pricing of intra group transactions across the product groups.
Indian tax laws have extensive requirement for maintaining documentation for related party transactions. The same also includes preparation of comprehensive study reports containing the group structure, economic analysis, FAR analysis, industrial outlook, determination of ALP, etc. The India regulation also requires usage of contemporaneous data for determination of ALP based on public databases. The firm has wide spectrum of subscribed database for carrying out the search process which include not only search for margins but also search for pricing the intangibles. At times the firm has used the associated enterprise situated outside India as the tested party requiring the firm to use international databases for the search of comparables. The firm has been active player and one of the leading service provider in this area since introduction of these regulations in India in the year 2001. As part of this service the firm has worked across industry segments, wide variety of transactions, applied all the permitted methods for determination of ALP and have also devised unique methods for justifying the ALP considering nature of set of transactions. The firm has experience of working on following type of transactions: