We have Partnered with TransPrice for an upcoming transfer pricing summit on 23rd of August, 2013. This presentation shares details of TransPrice as an entity.
4. About Transfer Pricing (1 of 2)
4
Transfer Pricing, worldwide is one of the most complex and challenging tax
domain which has a significant influence on the Company’s world wide
Effective Tax Rate
It impacts every element of supply chain – R&D, Procurement,
Manufacturing, Marketing, Distribution, Customer Support
Protection of tax base being the motive of every tax jurisdiction, balancing of
Transfer Prices has to be well backed up by pricing strategies and business
policies that are well documented and justified
India accounts for substantial portion in Transfer Pricing litigation around the
globe and is one of the countries having a strong view on the Transfer Pricing
law in global community
Evolving business structures necessitate review of Transfer Pricing models
and it is here that the Transfer Pricing solutions offered by TransPrice can
help you to achieve the desired business objectives
5. About Transfer Pricing (2 of 2)
5
1 Apr 12 31 Mar 13 30 Nov 13 30 Sep 14 31 Jan 17 31 Mar 23
Beginning
of Tax year
Close of
Tax year
Due date of
maintaining TP
documents and
Accountant’s report
Limitation of initial
assessment
Limitation of
completing TP
assessment
Requirement until
which FY 2012-13
documents required to
be maintained
Compliance and Documentation Timeliness
7. About TransPrice
7
TransPrice has its core focus on Transfer Pricing
steered by Transfer Pricing specialists to provide
you with tax optimal solutions
We understand that tax planning, compliance
and documentation requirements are the key
drivers
We add value with plethora of tax planning &
structural activities that helps you to achieve an
efficient tax structure, keeping in mind the law of
the land
Our extended team consists of dedicated
professionals being experts in the fields of
finance, taxation, accounting and law
Our Values
Technical Expertise
Core Focus
Empower Ideas
Customized Solutions
Continuous Learning
Knowledge Sharing
9. Practices
9
I. Planning, Advisory
and Structuring
II. Compliance and
Documentation
IV. Representation and
Dispute Resolution
V. Advance Price
Agreements
III. Specified Domestic
Transactions (SDT)
VI. Shared Services
11. I. Planning, Advisory and Structuring
11
Frame and review Transfer Pricing policy to evaluate and eliminate potential
risks, advice on pragmatic solutions and achieve optimal group taxability
Advice on profit margins to be maintained through benchmark analysis
Perform a high level diagnostic review in due diligence assignments
Review and preparation of intra group agreements and advice on the
appropriate pricing
Planning and Structuring Cost Sharing Arrangements
Planning and structuring on Group’s Functions, Assets and Risks
On call Transfer Pricing Advisory
Review of segmental profitability on a regular basis and suggest solutions
12. II. Compliance and Documentation
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Transfer pricing is all about comparability and documentation
A well framed TP strategy supported by documentation is the heart of
Transfer Pricing
We are a one stop solution for Transfer Pricing Documentation, including:
Identification of international transaction and Industry Analysis
Functional , Risk and Assets Analysis
Economic Characterization
Selection of most appropriate method
Benchmarking/ Economic analysis to select comparables
Determination of Arms Length Price
Conclusion
Preparation of preliminary benchmark studies
Transfer Pricing Accountant’s report – Form 3CEB
Transfer Pricing report drafting and generating back up documentation
13. III. Specified Domestic Transactions
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Phase 1: Advisory and Diagnostic
• Review of transactions, policies and agreements/ arrangements
• Development of transaction matrix
• Advice on applicability of SDT
Phase 2: Planning
• Functional analysis
• Economic Analysis
• Determination of Appropriate Transfer Pricing policy for SDT
Phase 3: Conclusion, Monitoring and compliance
• Monitoring on a quarterly basis for smooth implementation
• Compliance & Documentation in accordance with TP regulations
14. IV. Representation and Dispute Resolution
14
SC
HC
Income Tax
Appellate
Tribunal
CIT (A)
TPO/ AO
DRP
TPO/ AO
Coordination with legal council on
matters of substantial question of law
Representation before ITAT,
assistance in preparation of grounds
of appeal and background case
Representation and assistance in
building up the case file and
submissions
15. V. Advance Pricing Arrangements
15
Phase 1
Decide to enter the APA (feasibility analysis)
Phase 2
Prefilling consultation with the Tax Authorities
Phase 3
APA Application
Phase 4
Negotiation Stage
Phase 5
Finalization of APA
Phase 6
Furnishing of Annual Compliance Report
• Assistance in
undertaking the need
– time, cost, certainty
vs. Flexibility
• Assistance in
coordinating,
preparing and filing
application and
negotiating terms
with the authority
• Assistance in
compliance, audits,
review, renewal and
cancellation
16. VI. Shared Service Platform
16
We provide platform solution to you so that you get subject matter expertise
and cost synergies to maintain your transfer prices
We provide a complete Transfer Pricing solutions form a remote locations,
for e.g. off the self economic analysis that can be refined qualitatively as per
the clients requirements
We can act as your group’s TP cell, managing your transfer prices in the most
tax efficient manner
If you are a practicing accountant, we can act as your TP team
Complete back office TP solutions worldwide
18. Our Approach
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Our approach is ‘Client Centric’
We believe ‘ One Size fits no one’
We advocate specialization and believe that focus is vital for expert solutions
Especially in the field of Transfer Pricing, where every issue is unique as it
deals with different business scenarios, we tailor make the solutions for you
This helps you to create strong documentation and argue the case with the
tax authorities on business and economic grounds rather than being
monotonous with the same arguments year on year
We believe in proactively dealing with the issues rather than waiting for the
tax authorities to pick it. In this manner, you are well aware of the risk and
your position before the tax authorities
20. Our Group (1 of 2)
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Intellivate Capital, provides an entire spectrum of services in Investment
Banking, Project Management, Fund Raising and Management
Aurum Capital handholds the SME sector with structured and unstructured
debt to finance their operational activities through cash credit, working
capital and term loans
Manish Modi & Associates is a Chartered Accountancy firm providing
services in areas of Audit and Assurance, Compliance, Regulatory and
Consultancy including finance and tax consultancy
21. Our Group (2 of 2)
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TransPrice
TransPrice Solutions is a specialist organization, with core focus on Transfer
Pricing. It provides expert advisory, representation and compliance solutions
in Transfer Pricing arena
Brianna Knowledge Resources is a corporate training platform in the field of
finance. It is a creation of industry professionals who bring in a synergy of
knowledge bases and real time experiential learnings to the training platform
Pinnacle Education is a educational training institute molding thousands of
aspirants up to Final CA