Navigating the Arm’s Length Principle
Our bespoke approach ensures assistance at each level of transfer pricing life cycle, from pre-transaction planning & structuring to compliance and documentation

Over the last two decades, KCM has established itself in the Transfer Pricing domain by demonstrating its capabilities to formulate & honour Transfer Pricing requirements across the globe. Our team handles each stage of the transfer pricing life cycle with the objective to align the client’s business operations & objectives in a manner that meets with transfer pricing requirements in spirit & in law.

Our services include advising on the transaction, supply chain and pricing so as to have the client & its group entities comply with global transfer pricing requirements. We have wide experience in handling various structuring cross-border transactions of tangibles, intangibles, and services and inbound and outbound investments.

We have a dedicated team of Transfer Pricing professionals serving clients for meeting Indian as well as Global Transfer Pricing requirements. We cater to more than 15 jurisdictions for carrying out benchmarking evaluation and preparation of transfer pricing documentation complying with local requirements.

Proliferating international transactions in this stimulated global business environment has led to complexities in business transactions. The diverse and dynamic transfer pricing regulations add to the transfer pricing risk for multinationals operating on a global scale.

Our team can assist you in preparing a Group Transfer Pricing Policy based on benchmarking evaluation, which would help entities across the group in streamlining their transfer pricing documentation according to transfer pricing requirements, and at the same time. This approach helps a group in having synchronised transfer pricing positions and documentations across jurisdictions while at the same time helping groups eliminate multiplicity of costs at different locations.

We can also assist you with the Implementation of Transfer Pricing Policy and mitigate operational issues if any, that crop up during implementation.

As diverse and dynamic as transfer pricing can be, the principle continues to be driven by Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations issued by the OECD.

Value chain analysis refers to the evaluation of functions, assets, risks of the group as a whole and the contribution of various group entities to the group’s value drivers. Value chain analysis helps in setting Group Transfer Pricing Policy in a complex business environment and helps align business returns to the entities that drive the business.

Our team can help the clients in carrying out a detailed Value Chain Analysis and realign intra-group arrangements to assign returns where value is being created. We can assist with transaction / corporate (re)structuring for efficient value chain management.

We can assist companies at various levels of transfer pricing compliance, including

  • High-level review of benchmarking and/or documentation prepared by the MNE
  • Benchmarking for transactions like royalty, service fees, financing arrangements, or other operational / business transactions
  • Preparation of transfer pricing documentation
  • Local filing of transfer pricing report
  • BEPS Action 13 Compliance - Preparation of Country-by-Country Report / Master File

In an ideal situation, transfer pricing policies and compliance within the group should be synchronised with each other. A harmonised transfer pricing solution includes services from transaction planning to preparation of documentation for all entities such that each documentation is aligned to the group master file as well as to the flip-side documentation by other entity to the transaction. Our services include -

  • Preparation of Group Master File
  • Assistance in preparation of CbCR for the Group
  • Preparation of synchronised Local File(s) with harmony between the Master File and transactions documented from a flip-side perspective
  • Preparation and maintenance of position papers to support the transfer pricing evaluation carried out at a group level

An exhaustive and analytical understanding of group as well as entity’s business is essential to defending client positions before the tax office. Our team, with its vast experience before various tax forums, is adept with preparing a defense strategy for the client’s positions and represent the matter so as to provide our clients with best possible defense.

Our services in this respect include -

  • Preparation of safe harbour applications & representation before Safe Harbour Authority
  • Advisory & assistance in representation before the Transfer Pricing Officer
  • Representation before the Dispute Resolution Panel and Income-tax Appellate Tribunal
  • Assistance in counsel briefing and litigation management for representation before HC and SC
  • Preparation of application for Mutual Agreement Procedure (MAP) or Advance Pricing Arrangements (APA) and assistance in submission of required details at appropriate fora
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