Transfer Pricing

Transfer pricing is the practice of setting prices for transactions between related entities within a multinational company. It ensures that goods, services, and intellectual property are priced fairly and at arm's length, aligning with regulatory requirements while optimizing tax strategies. Explore how we navigate this complex landscape to maximize value and compliance for your business.

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Global Documentation

This entails providing assistance in complying with local and global

TP planning, documentation and assistance with compliance

This entails developing TP strategies and providing assistance in meeting documentation and compliance requirements on Advance Pricing Arrangements (APA) scheme, Safe Harbour Rule and to meet new documentation and reporting requirements viz. Country by Country Reporting ‘CbCR’ and the Master File.

TP controversies and dispute resolution management

Assistance in TP audit support services and in preparing and briefing for proceedings before the Commissioner of Income Tax

Value Chain Management

This entails helping companies integrate tax planning into business operations to help maximize growth opportunities, minimize expenses.

Base Erosion Profit Shifting (“BEPS”)

We can assist in compliance with BEPS guidelines i.e. a global tax avoidance strategy used by multinational companies to shift profits to low-tax jurisdictions, reducing their overall tax liabilities.

Domestic TP

Assistance in compliance with Domestic TP provisions, similar to international transfer pricing regulations as introduced by the Finance Act, 2012.

700 +

Trusted Clients

7 +

Awards

34 +

Years of Experience

115 +

Experts

Transfer Pricing Process at Accorp Partners:

Assessment

: We start by assessing your company's global operations, intercompany transactions, and industry-specific factors to understand your transfer pricing needs.

Planning

Our experts develop a tailored transfer pricing strategy that aligns with your business goals, complies with local and international regulations, and minimizes tax risks.

Documentation

We assist in creating comprehensive documentation, including master files, local files, and specific country documentation, to support your transfer pricing positions.

Benchmarking Analysis

Our team conducts thorough benchmarking studies to compare your transfer pricing results with external, arm's length transactions, ensuring compliance and justifiable pricing.

Compliance

We help you navigate the complex compliance requirements of different jurisdictions, ensuring that your transfer pricing practices adhere to local regulations and international standards.

Advanced Pricing Agreements (APAs):

If beneficial, we can negotiate and secure Advance Pricing Agreements with tax authorities to provide certainty and reduce the risk of disputes.

Safe Harbour Compliance

We guide you in utilizing Safe Harbour provisions when applicable, streamlining compliance and reducing uncertainty

Dispute Resolution

In the event of a dispute, we offer expert support in negotiations and resolution with tax authorities to protect your interests.

Continuous Monitoring

We provide ongoing monitoring and updates to ensure that your transfer pricing strategies remain aligned with evolving regulations and market conditions.

Value Optimization

Our ultimate goal is not only compliance but also optimizing your global value chain to enhance profitability while managing tax exposure.

Our Clients

OUR TESTIMONIALS

Working with Accorp Partners, transfer pricing experts was a game-changer for us. They made complex international transactions and tax compliance feel effortless. Their guidance in method selection, documentation, and securing Advance Pricing Agreements was invaluable. Our bottom line has improved, and I wholeheartedly recommend their services.

- Sarah Brown, CFO, Export Company

Accorp Partners have been an essential asset for our multinational business. Their knowledge and expertise in transfer pricing have not only helped us navigate complex international tax laws but have also significantly improved our financial transparency. With their guidance, we've optimized our tax position and mitigated risk. Engaging with them has been a game-changer

- Alex Chen, Finance Director, Venture Capitalist Company.

Featured Resources

Tax Efficiency: Advanced Transfer Pricing Strategies.

Expanding your business globally is a significant step, and choosing the right location is crucial for success.

Transfer Pricing and BEPS: Implications for US Businesses.

Transfer pricing has long been a critical area of focus for multinational enterprises (MNEs) conducting cross-border transactions.

Transfer Pricing Risk Assessment: Mitigating Risks in the US

Transfer pricing risk assessment is a critical process for businesses operating in the United States.

Our Team

Tripti Goel

CA, B Com (Hons),
M Com

Vikas Bansal

CA,B.com

FREQUENTLY ASKED QUESTIONS

Why is transfer pricing important?

Transfer pricing is crucial for determining how profits are allocated among different entities within a multinational group, which can impact tax liabilities, compliance, and financial reporting.

What is the primary objective of transfer pricing regulations?

The primary objective is to ensure that transactions between related entities are priced fairly and at arm's length, meaning the prices are comparable to what unrelated parties would pay in similar transactions.

What are controlled transactions and uncontrolled transactions in transfer pricing?

Controlled transactions involve transactions between related parties, whereas uncontrolled transactions involve transactions between unrelated parties.

What happens if transfer pricing rules are not followed?

Non-compliance with transfer pricing rules can lead to tax adjustments, penalties, double taxation, and disputes with tax authorities.

What are the common transfer pricing methods?

YesCommon methods include Comparable Uncontrolled Price (CUP), Resale Price Method (RPM), Cost Plus Method (CPM), Transactional Net Margin Method (TNMM), Profit Split Method, and others.

How do I determine which transfer pricing method to use?

The choice of method depends on factors like the nature of the transactions, availability of comparable data, and the specific regulations in each jurisdiction.

What is Advance Pricing Agreement (APA)?

An APA is an agreement between a taxpayer and tax authorities that establishes the transfer pricing method and pricing for a set of transactions in advance, providing certainty and reducing the risk of disputes.

What are the documentation requirements for transfer pricing compliance?

Documentation typically includes detailed records of the controlled transactions, the method chosen, and the analysis supporting the pricing.

How do I handle transfer pricing in a global business context?

In a global context, transfer pricing can become complex due to different tax laws and regulations in various countries. Multinational companies often seek expert advice and employ strategies to ensure compliance and minimize tax risks.

What are the penalties for transfer pricing violations?

Penalties for transfer pricing violations can include fines, interest on underpaid taxes, and the possibility of audits and investigations by tax authorities.

Can transfer pricing lead to double taxation?

Yes, if tax authorities in different countries have different views on the appropriate transfer prices, it can lead to double taxation. However, double taxation can often be mitigated through tax treaties and dispute resolution mechanisms.

What is the role of a transfer pricing or expert?

Transfer pricing experts provide guidance on compliance, help select appropriate methods, perform economic analyses, and assist in negotiations

What is Safe Harbour in transfer pricing?

Safe Harbour is a mechanism that allows businesses to simplify their transfer pricing compliance by providing predetermined acceptable profit margins or pricing methods for certain types of transactions, reducing the risk of disputes with tax authorities.

What is Country-by-Country Reporting (CbCR)?

Country-by-Country Reporting requires multinational companies to report detailed financial and tax-related information for each country in which they operate. It aims to enhance transparency and help tax authorities assess transfer pricing risks.

INCORPORATION