International Taxation

1. Transfer Pricing Analysis

  • In-depth review and analysis of intercompany transactions to ensure alignment with the arm's length principle.
  • Assessment of the nature and scope of related party transactions across jurisdictions.
  • Detailed evaluation of available transfer pricing methods as prescribed under the Income Tax Act and OECD Guidelines.
  • Recommendation and justification of the most suitable method based on the specific facts and circumstances of each transaction.

2. Benchmarking Analysis

  • Identification of comparable companies and transactions using robust databases and industry standards.
  • Preparation of benchmarking reports to substantiate pricing of intercompany transactions.

3. Issuance of Statutory Certificates

  • Preparation and issuance of Form 3CEB as required under Section 92E of the Income Tax Act, 1961.
  • Ensuring timely and accurate compliance with statutory reporting obligations.

4. Transfer Pricing Documentation & Policy Support

  • Assistance in drafting, reviewing, and updating transfer pricing policies tailored to the client's business model and industry.
  • Preparation and maintenance of comprehensive transfer pricing documentation (Local File, Master File) in line with Indian regulations and global best practices.
  • Adapting documentation to meet evolving requirements, including Country-by-Country Reporting (CbCR) under the BEPS (Base Erosion and Profit Shifting) initiative.

5. Representation & Litigation Support

  • End-to-end representation before Transfer Pricing Officers (TPOs), Dispute Resolution Panels (DRPs), and Appellate Authorities.
  • Preparation of submissions, responses to notices, and support during audits and assessments.

6. Advisory on Safe Harbor Rules

  • Analysis of eligibility and benefits under Safe Harbor provisions.
  • Guidance on compliance requirements and strategic advice on adoption of Safe Harbor Rules to mitigate transfer pricing risks.

7. Advance Pricing Agreements (APA)

  • Assistance in evaluating the feasibility of entering into unilateral, bilateral, or multilateral APAs.
  • Support in preparation, negotiation, and implementation of APAs to ensure long-term certainty on transfer pricing positions.

8. Risk Assessment & Planning

  • Identification of potential transfer pricing risks and exposures.
  • Strategic planning and structuring of intercompany transactions to optimize tax efficiency and minimize disputes.

Other Services

Expat Taxation - Preparation of Computation of Income Tax and filing of Income Tax Return, Advisory on Taxation Matters and other related matters.

Cross Border Tax Structuring and Advising on Global Tax Matters.

Advising and providing Opinions on various DTAA issues.

UAE TRANSFER PRICING SERVICES

  • Transfer Pricing Advisory and Risk Assessment: Evaluation of intercompany transactions to identify risks and ensure alignment with the arm’s length principle, minimizing the risk of disputes with tax authorities.
  • Transfer Pricing Compliance: Assistance with meeting regulatory requirements, including preparing and maintaining documentation as mandated by UAE law.
  • Transfer Pricing Documentation: Preparation of required documents such as the local file, master file, and country-by-country report, in line with OECD guidelines and UAE regulations. This includes detailed descriptions of related party/ connected person transactions, transfer pricing methods, and supporting analysis.
  • Due Diligence and Benchmarking: Analysis and comparison of intercompany pricing against market data to support arm’s length pricing.
  • Transfer Pricing Planning and Modelling: Structuring and simulating intercompany transactions to optimize tax positions and ensure compliance with evolving business models.
  • Disclosure Form Preparation: Assistance in preparing and submitting the required transfer pricing disclosure forms as part of the corporate tax return, providing authorities with transparency over intercompany transactions.
  • Litigation and Dispute Resolution: Support in case of disputes with tax authorities regarding transfer pricing practices.
  • Tax Optimization and Business Transformation: Strategic advice to minimize tax liabilities while remaining compliant with transfer pricing rules
 
     
7423 Times Visited