Transfer Pricing

    In globalised environments, cross-border transactions are increasing in number and complexity and transfer pricing outcomes need to in line with business value creation. Significant increase in transfer pricing disputes and a global focus on base erosion and profit shifting has ensured transfer pricing is a focus area for all stakeholders. It is our view that strategic dispute management (such as through APAs or alternative resolution techniques) on a global basis will become increasingly crucial in companies’ efforts to sustain their global transfer pricing strategies.

    Organisational challenges

    • Documentation in alignment with global jurisdictions
    • Planning and documentation of transfer pricing policy and procedures
    • Manage cross-border effective tax rate during a business expansion or transformation
    • Mapping the allocation of value across the entire supply chain
    • Know whether internal controls over transfer pricing are sufficient and how they can be improved
    • Manage transfer pricing and customs risk concurrently
    • Defend transfer prices before the tax authorities
    • Address challenges arising out of domestic transfer pricing rules
    • Managing compliance under the Companies Act 2013/Clause 49 of the SEBI listing guidelines
    • Aligning documentation under the country-by-country reporting in the Base Erosion & Profit Shifting initiative

    Our services

    We help you in the following:

    • Develop transfer pricing documentation and defence files, coordinated across all your territories and harmonised with Indian Customs regulations
    • Transform the value chain to achieve sustainable financial and operational benefits, supply chain efficiencies and align operational, tax and legal structures
    • Develop better understanding of your transfer pricing risks, and implement consistent and defensible practices when controversies do arise
    • Develop strategies at both the global as well as local levels and guide you through the process of requesting APAs to help ensure successful outcomes
    • Assistance in setting up a governance framework for determining arm’s length pricing consisting of related party contracts as per the Companies Act 2013/Clause 49 of the SEBI listing guidelines
    Gautam Mehra, Leader, Tax, PwC India
    Gautam Mehra
    Tax Leader
    Tel: +91 22 6119 8051