Transfer Pricing

Increasing numbers of intercompany transactions have made transfer-pricing a leading risk management issue for international businesses. The lawsuit in India on account of this is humongous. NKRJ & Associates aim to facilitate businesses by providing practical transfer pricing solutions that are allied to their international business and also run controversy management. Our transfer pricing team has methodical expertise and familiarity to support transfer pricing matters for the clients which mainly includes:

Indian Transfer Pricing Support Advisory

Transfer Pricing Study/advisory for new transactions or specific transaction including
Intangibles
Loans and Guarantees
Intra Group services
Payments Development Centres
R&D Centres
Restructuring or Reorganization
Purchase or sale of marketable securities etc.
Development of better understanding of risks associated with transfer pricing (functions)
Formulation and Implementation of domestic and global transfer pricing policies

Managing Transfer Pricing Controversy

Assistance in all the stages the entire lifecycle of Advance Pricing Agreement (APA) comprising of pre filing consultation, filing of APA application, negotiation and preparation of mutually agreed draft agreement.
Representation before Transfer Pricing Officer (TPO), Commissioner Income Tax (Appeals), Dispute Resolution Panel and Income Tax Appellate Tribunal in the case of transfer pricing assessment or appeals
Assistance in Mutual Agreement Procedure ("MAP")
Assistance in application of Safe Harbour Rules