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 or tax risks.
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 in GCC and EU have also adopted such principle of Disclosure Form thereby reducing burden on the Tax Authorities for preliminary review of the International Transactions.
We have helped our clients in their Indian transfer pricing documentation, global transfer pricing documentation, drafting of Function, Asset and Risk analysis (FAR), drafting of company and group overview, updating of Industry analysis for the industry in which they are operating, determination of Arm’s Length Price, comparability analysis, ensuring their transfer pricing audits and form 3CEBs.
We have also assisted our clients in providing transfer pricing certifications and comfort letters, special transaction benchmarking and documentation such as royalties, interest rates, management services, etc., preparation of their group global master file and making amendments related to additional requirements under Indian regulations, preparation of Country-by-Country Reporting (CbC Reporting) report.
For clients who have units or operations in tax holiday, startup or the new manufacturing tax holiday