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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