Transfer Pricing Documentation

Once the International Transactions are entered throughout the year, it is imperative to undertake the Transfer Pricing Documentation to record the Arm’s Length Price and Comparability Analysis post the year end. Such an analysis is the ultimate proof that the transactions entered between the Associated Enterprises are at an Arm’s Length Price and there is no potential tax avoidance. Specific to India, the onus to verify the Transfer Pricing Documentation is on an independent Chartered Accountant, who undertakes a Transfer Pricing Audit and provides his opinion in the form of a certificate in Form 3CEB (Disclosure Form). Many countries like Saudi Arabia have also adopted such principle of Disclosure Form thereby reducing burden on the Tax Authorities for preliminary review of the International Transactions.

Our solutions in the Transfer Pricing Documentation include:

  • Indian Transfer Pricing Documentation
  • Global Transfer Pricing Documentation
  • Drafting of Function, Asset and Risk analysis (FAR)
  • Company and Group Overview
  • Industry Analysis
  • Determination of Arm’s Length Price
  • Comparability Analysis
  • Ensuring Transfer Pricing Audits and Form 3CEBs
  • Transfer Pricing Certifications and Comfort Letters
  • Special Transaction Benchmarking and Documentation such as Royalties, Interest Rates, Management Services, etc.
  • Preparation of Global Master File
  • Preparation of Local files for Indian Transfer Pricing and Global Transfer Pricing
  • Country-by-Country Reporting (CbC Reporting)
  • Safe Harbour Documentation
  • Filing of Income-Tax Returns and Tax Declarations for Non-Residents
  • Transfer Pricing Documentation and Transfer Pricing Audits in Form 3CEBs for Foreign Companies
  • Update of Benchmarking Studies
  • Specified Domestic Transactions
  • E- benchmark Facility through the website