Strategic planning for intercompany transactions
Compliance with OECD guidelines and Indian TP regulations
Value chain analysis and risk assessment
Preparation of Master Files, Local Files, and Country-by-Country (CbC) reports
Functional and comparability analysis
Assistance with Form 3CEB filing and regulatory submissions
Representation before Transfer Pricing Officers (TPOs), CIT(A), DRPs, ITAT
Drafting submissions and appeals
Optimization of royalty payments, management fees, and intercompany financing
Structuring related-party transactions for tax efficiency
Profit attribution studies for permanent establishments (PEs)
Tailored TP strategies for IT, pharmaceuticals, manufacturing, and financial services
Benchmarking studies using TP Catalyst and Orbis databases
Compliance with BEPS Action Plans and evolving tax regulations.