[Transfer Pricing Expert]

India

11 + years in Transfer Pricing Work

Relevant experience of 11+ years in a big four firm handling a number of Transfer Pricing assignments ranging from compliance, litigation, benchmarking and planning for the inbound and outbound multinational companies in verticals including Manufacturing, Pharmaceutical, Information Technology, Infrastructure, etc.
• Benchmarking analysis
Review and analysis of benchmarking sets and customization on the basis of specific profile of the client through quantitative and qualitative adjustments.
• Planning Assignments
Transfer price determination for the proposed/existing international and domestic related party transaction/s to align with the arm’s length standard as per the existing Transfer Pricing Regulations.
• Assessment/ Litigation support
Preparation of submission/application/appeal on notices/orders/directions of the Transfer Pricing Officer, Dispute Resolution Panel, Commissioner of Income Tax (Appeals) and Income Tax Appellate Tribunal.
• Annual Compliance including
Form 3CEB
Complete identification and review of international and domestic transactions with related parties through documentation examination (viz., financials, intercompany agreements, work orders, invoices, debit and credit notes etc.) relevant to the transactions, required to be reported in Form 3CEB.
Transfer Pricing Memorandum
Analysis and documentation of Functional, Asset and Risk analysis (FAR) relevant to international and domestic transactions. Devising and application of benchmarking analysis based on FAR and industry analysis relevant to the transactions.

Master File
Overview and documentation of relevant information on the basis of global operations, inter-company transactions, transfer pricing policy and FAR within the overall framework of Multi-National Corporations, based on Indian Regulations/ OECD BEPS Action 13 of guidance report.
Country By Country Reporting
Tax jurisdiction-wise reporting in accordance with OECD BEPS Action 13 of guidance report.
Companies’ Act Compliance
Analysis, benchmarking and testing of related party transactions along with recommendations.
• Advance Pricing Agreement (APA)
Filing and furnishing application for pre-filing and main filing and preparation of presentations/submissions for miscellaneous questionnaire/s issued and site visit during the course of negotiations.
• Global documentation
Preparation of global transfer pricing documentation consistent with the respective jurisdictional Transfer Pricing Regulations and OECD guidelines.