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In Transfer Pricing, the defense mechanism from the Taxpayer’s perspective is an essential element where the Tax Authorities calls for Transfer Pricing Documentation where an Arm’s Length nature of transaction needs to be proven. Such a defense mechanism could be proactive or reactive.
Our solution in the Transfer Pricing dispute resolution include:
In Transfer Pricing, the defense mechanism from the Taxpayer’s perspective is an essential element where the Tax Authorities calls for Transfer Pricing Documentation where an Arm’s Length nature of transaction needs to be proven. Such a defense mechanism could be proactive or reactive.
Our solution in the Transfer Pricing dispute resolution include:
We understand the complexities and challenges involved in transfer pricing and tax disputes. Our expert team of dispute resolution specialists is here to help you navigate through any conflicts that may arise. With our comprehensive understanding of international transfer pricing regulations and our proven track record of successfully resolving disputes, we are dedicated to providing you with the best possible outcome. Trust us to handle your transfer pricing disputes with professionalism, expertise, and utmost confidentiality.
We assist in representing your case before the transfer pricing authorities in India. The ideal way to represent is to think through the strategy and essential elements in the transfer pricing case to understand if there are any risk areas which could be pre-identified and accordingly addressed. Such analysis could only come through a specialist experience.
APA is a proactive way of reducing the future litigation at the multinational company. It is entering in to an agreement with the Central Government declaring and fixing your transfer pricing mechanism. One can get clarity on 9 years of transfer pricing due to execution of such APA. We assist multinationals in end-to-end processing of the APAs with the Government.
Once the taxpayer opts for the safe harbour regulations, the tax authorities through its transfer pricing officers may like to understand whether the application is a valid application or shall be rejected. We assist companies with representations before the transfer pricing authorities to explain the positions undertaken by the clients and accordingly justify the option of safe harbour.
Clients may have their internal litigation experts and litigators on their board. They often reach out to us for a formal strategy build up around transfer pricing litigation strategy and take prior approvals of their strategy from the firm.
DRP is the 1st level appellate authority for transfer pricing matters. We assist our clients with preparation for the appeal, application for the appeal as well as representations for the appeal.
We assist our clients with strategizing, drafting and active representations at the tax tribunal level. Tax tribunals are an important level in tax litigation, as it is the final fact-finding authority. It is essential that all facts are well placed before this level and argued accordingly. We work with a panel of litigation experts along with in-house experts at TransPrice.
We facilitate our clients for appeals at a higher level where we study the case, strategise and brief the counsel for the case at High Court and Supreme Courts.
We undertake detailed review of the documentation undertaken by the taxpayer in the past and understand the risk involved in the model and the documentation. We suggest the corrective action for bringing the transfer pricing in alignment for past and for future.
Do you need assistance with your transfer pricing issues, or would you like to know more about us? Please click here.
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