Transfer Pricing

Get complied with transfer pricing provisions under Income Tax Act,1961 by filing the form 3CEAB and Transfer pricing study report. Contact with KNAP Advisory specialists immediately to complete the task successfully.

Documents required

  • Access to books of accounts
  • Intercompany documents (sales/purchase/others)
  • Agreement between associate enterprises

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Transfer Pricing

Overview - Transfer Pricing

Businesses that do business in more than one country are finding it harder and harder to keep track of and follow local laws. Businesses have to spend more time and money to keep up with the changes in their local tax environment. Transfer pricing (TP) is one of these important things for businesses that do business around the world. Organizations need to think about the TP issues that come up with intragroup transactions, no matter how big or small they are, and they need to put in place a strong, effective, and reliable TP approach.

KNAP’s TP practise is made up of experts who offer a wide range of services, such as helping plan, streamline, manage, and solve complex issues to reduce TP risk and make sure they are in line with the client's global business strategy and goals.

Our TP team has the skills and experience to provide complete solutions in areas like TP documentation, compliance and certification, advisory services, dispute resolution mechanisms, due diligence, litigation support, drafting and reviewing inter-company agreements, value chain review, global benchmarking assistance, etc.

We uses the following core strengths to come up with unique ways to help businesses solve their problems:

  • A close-knit group of partners, with each project led by TP experts who are qualified and committed to their jobs.
  • Having a deep understanding of the industry from doing complex TP work for clients in many different market sectors.
  • Using a holistic, multidisciplinary approach to give multinational companies (MNCs) solutions that are consistent, efficient, and strong and meet all of their needs.
  • Adopting a cutting-edge technology platform and advanced databases/tools paves the way for a digitally driven transfer pricing function.
  • Quality of services given in line with best practises and international standards

Transfer Pricing Methods

Comparable Uncontrolled Price (CUP) method

The comparable uncontrolled price method compares the price and terms of goods or services in a controlled transaction between related parties with those in an uncontrolled transaction between independent enterprises. For the CUP method to be able to make this comparison, the transaction between the associated enterprises must be very similar to the transaction between two independent enterprises.

Resale Price Method

The selling price of a good or service is used in the resale price method. This price is also called the resale price. This amount is then subtracted by a gross margin, which is calculated by comparing the gross margins of similar transactions made by organisations that are not related to each other but are similar. Then, the costs of buying the item, like customs duties, are reduced from the total. The final number is considered to be a arm’s length price for a controlled transaction made bet

The Cost-Plus Method

The cost-plus method looks at a controlled transaction between a buyer and a seller who are related. It is usually used when two related companies trade semi-finished goods or when two related companies have long-term agreements to "buy and supply." The supplier's costs are added to the markup for the product or service so that the supplier can make a fair profit based on the tasks they did and how the market is doing at the time. The arm’s length price for the transaction is the sum of the tw

Transactional Net Margin Method

The Transactional Net Margin Method looks at the net profit of a transaction between related parties to help figure out transfer prices. Then, this net profit is compared to the net profits of similar transactions of enterprises that are not related to each other. This method is the most common and widely used type of transfer pricing method, because transactions don't have to be exactly the same as the controlled transactions to be considered comparable.

Revenue authorities all over the world are taking different steps to improve documentation to make international transactions between Group companies easier to track. India's TP rules also require that you keep very detailed records, and if you don't, steep penalties will be imposed.

We assist our clients in meeting the requirements for paperwork by offering the following services:

  • Review any documentation that the client already has, if any.
  • Advising clients to keep key data points that are important for putting together documentation
  • Help with making internal rules and procedures to make sure documentation requirements are met
  • Doing detailed industrial, functional, and benchmarking analyses as part of the documentation
  • Making sure that the TP documentation is complete and strong

Preparing the Local File and Master File according to the laws of the country and the OECD Guidelines

As the global tax system is always changing, tax authorities are always putting in place new rules for disclosure and compliance. Revenue authorities keep a close eye on how well MNCs follow these compliance requirements to see if they don't.

BDO India offers a wide range of compliance and certification services to its clients. Some of these services are:

  • Providing TP certification (Accountant's Report) in Form 3CEB.
  • Giving advice on the Master file and Country-by-Country (CBC) reporting requirements and whether or not they apply.
  • Help with making the Master file and CBC report and filing them (Form 3CEAA, 3CEAB, 3CEAC, 3CEAD and 3CEAE)

When dealing with TP issues, MNCs that do business in a number of key tax jurisdictions often face problems. To deal with and defend against these problems, the current intercompany arrangements need to be reviewed, a strategic TP planning exercise needs to be done, and a consistent global TP approach or policy needs to be put in place to meet the needs of each tax jurisdiction.

We at KNAP, can help in this way by offering the following TP advisory services:

  • Routine TP advisory services
  • Help in setting up or reorganising the TP operational model
  • Perform a due diligence check on TP
  • Advice on alternative business models and help with implementation.
  • Reviewing the pricing method and benchmarking analysis for new intra-group transactions.
  • Documenting the global TP policy
  • Advice on financial transactions, cost-sharing arrangements, and other complex transactions.
  • Advice on intangibles and intellectual property migration.
  • Review of deemed international transactions.
  • Advice on structure management fee payments, royalty payments, etc.

 

HELP & FAQs

What is transfer pricing

Transfer pricing is the price charged for the transfer of goods or services between related parties, such as a parent firm and its subsidiary, or between subsidiaries of the same parent company. The goal of transfer pricing is to ensure that transactions between connected parties are handled at arm's length, i.e., at the same price that would be charged for a transaction between unrelated parties.

Why is transfer pricing important?

Transfer pricing is crucial since it can significantly affect a company's tax liability. If a enterprise uses excessively high transfer prices, it might artificially reduce its taxable income in one jurisdiction while increasing it in another. If a enterprise sets transfer prices that are excessively low, it might raise its taxable income in one jurisdiction while decreasing it in another. This can lead to tax authorities in various jurisdictions disputing over the transfer prices, which could result in double taxation or other penalties.

What are transfer pricing services?

Transfer pricing services relate to the consulting and advising services provided by specialists to businesses in order to assist them in ensuring compliance with transfer pricing legislation, optimising their transfer pricing policies, and mitigating the risk of tax authority disputes. These services may include transfer pricing paperwork, benchmarking study, transfer pricing strategy, dispute resolution, and audit defence.

Are transfer pricing services mandatory in India?

Yes, transfer pricing documentation is required for certain types of transactions in India. The Indian transfer pricing requirements compel taxpayers to retain evidence demonstrating arm's-length transfer prices. Noncompliance with transfer pricing requirements may result in penalties and interest fees.

Who provides transfer pricing services in India?

A variety of specialists, including accounting firms, legal firms, and specialised transfer pricing consulting firms, offer transfer pricing services in India. These experts may specialise in tax, accounting, economics, or law, and they may be located in India or in other nations. At KNAP Advisory, we have team of Chartered Accountants who specialised in the transfer pricing and have already worked with MNCs and other entities.

Why KNAP Advisory for Transfer Pricing services ?

Tax specialists and chartered accountants at KNAP Advisory always ensure that both interested parties adhere to transfer pricing regulations. We offers transfer pricing certificates to businesses engaging in international or even some specific domestic transactions.

Our team of seasoned legal and tax professionals provides industry-specific advice on transfer pricing provisions. Our transfer pricing reports and audits are conducted only after a thorough analysis of all relevant documents and information to confirm the accuracy of each transaction's specifics.

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