Transfer Pricing Advisory
WHAT WE DO
We advise businesses on transfer pricing policies, intercompany arrangements, and arm’s length pricing methodologies, aligning tax positions with commercial realities and applicable regulations.
HOW WE HELP YOU
We help you identify transfer pricing risks, establish appropriate pricing policies, evaluate alternative approaches and structures, and develop defensible positions that support your business model while reducing the likelihood of litigation.
Transfer Pricing Compliance
WHAT WE DO
We manage transfer pricing documentation and compliance requirements, including Local Files, Master Files, Country-by-Country Reporting (CbCR), and applicable statutory filings.
HOW WE HELP YOU
We ensure your intercompany transactions are supported by consistent, transaction-specific documentation and appropriate economic analysis, helping you meet filing obligations and respond confidently to scrutiny from tax authorities.
Benchmarking Report
WHAT WE DO
We conduct economic and financial benchmarking using recognised databases, appropriate comparability criteria, and established transfer pricing methodologies to evaluate the arm’s length nature of related-party transactions.
HOW WE HELP YOU
We help you establish supportable pricing ranges and mark-ups, substantiate intercompany charges, evaluate the appropriateness of pricing policies, and build evidence-based documentation to support your tax positions.
KMP Remuneration Transaction Advisory
WHAT WE DO
We provide specialised advisory on the remuneration of Key Managerial Personnel (KMP) and directors in related-party arrangements, including functional assessments, benchmarking, economic analysis, and supporting documentation.
HOW WE HELP YOU
We help you evaluate whether remuneration arrangements are commercially justified and supportable under applicable rules, establish appropriate benchmarking, and maintain documentation to substantiate remuneration decisions during tax assessments and regulatory reviews.
Pillar Two Assessment and Compliance
WHAT WE DO
We assist multinational enterprise groups in assessing their obligations under the OECD Global Anti-Base Erosion (GloBE) Rules, including safe harbour assessments, jurisdictional computations, and top-up tax compliance, where applicable.
HOW WE HELP YOU
We help you evaluate potential exposure to the global minimum tax, identify relevant safe harbour opportunities, assess data and reporting requirements, and prepare for applicable compliance obligations with clarity.
Transfer Pricing Litigation Support
WHAT WE DO
We provide technical support throughout transfer pricing assessments, tax audits, dispute resolution, and appellate proceedings, including matters before Transfer Pricing Officers (TPOs), Dispute Resolution Panels (DRPs), and appellate authorities.
HOW WE HELP YOU
We help you prepare a strategy around potential / ongoing litigation, develop evidence-backed arguments, prepare submissions, evaluate litigation strategies, and build a strong technical defence to protect your interests throughout the litigation.
Cross-Border Transaction Advisory
WHAT WE DO
We advise on the tax implications of cross-border transactions, including intercompany provision or receipt of services / sale / purchase, financing arrangements, business restructuring, international investments, withholding taxes, and permanent establishment exposure.
HOW WE HELP YOU
We help you evaluate tax implications before executing transactions, assess treaty benefits and compliance requirements, identify potential tax exposures, and structure cross-border arrangements that align with your commercial objectives.
GCC Set-up in India
WHAT WE DO
We advise businesses establishing Global Capability Centres (GCCs) in India on tax considerations, entity structuring, transfer pricing policies, intercompany arrangements, and operating models.
HOW WE HELP YOU
We help you evaluate suitable operating structures, define intercompany service arrangements, establish appropriate remuneration models, and develop tax and transfer pricing frameworks that support efficient operations and sustainable growth in India.
Advance Pricing Agreements (APA)
WHAT WE DO
We advise businesses on the feasibility, strategy, and execution of Advance Pricing Agreements to establish agreed transfer pricing methodologies for eligible international transactions.
HOW WE HELP YOU
We help you assess the suitability of an APA, evaluate potential pricing methodologies, prepare FAR and economic analysis and supporting documentation, and navigate the engagement process with tax authorities to pursue greater certainty and reduce future transfer pricing disputes.