Transfer Pricing Consultant

AnBac Advisors is a leading name in the Transfer pricing consultancy for Price setting, compliances and negotiating APAs in India. Price setting for global transactions involves consideration of Transfer pricing regulations of both countries, as well as valuation principles associated with industry.

At AnBac Advisors, an expert team of Transfer Pricing consultants, helps to carry out compliances of Form 3CEB for certification and justification of international transactions undertaken with related parties. Our team has had great success in establishing Arm’s length transactions during Transfer Pricing litigations at Transfer Pricing Assessment Officer, CIT(A) and ITAT levels.

As an experienced transfer pricing consultant, our services include:

• Transfer Pricing Documentation – Transfer pricing legislation requires the computation of the international transactions between the associated parties to be calculated at the arm’s length price i.e. the price of similar international transaction between unrelated enterprises. The Transfer Pricing Document created by Anbac Advisors covers all the requirements stated under the law.
• Review of existing documentation/Policy – As an transfer pricing consultant, we undertake a thorough review of an enterprise’s existing TP documentation or policy in order to update or strengthen the policy.
• Representation before Transfer Pricing Authorities for tax audit procedures.
• Transfer Pricing Planning – We provide assistance in developing and implementing viable transfer pricing policies which are in harmony with the existing transfer pricing policy, acquiring new TP structures.
• Assessing the global transfer pricing controversies and mitigating a strategy for risk management.
• Advisory related to international tax and international transactions to avoid double tax treaties.

Transfer Pricing Challenges

Transfer pricing poses various challenges for multinational corporations and tax authorities. Some of the key challenges include:

1. Complexity and Diversity: Transfer pricing involves complex transactions, and each transaction may be unique. Multinational companies often have diverse business operations, making it challenging to find truly comparable transactions for benchmarking purposes.
2. Global Regulatory Variations: Transfer pricing regulations vary widely across countries. Navigating and complying with different rules and regulations in multiple jurisdictions can be challenging for multinational companies, leading to a risk of double taxation or disputes with tax authorities.
3. Rapidly Changing Regulations: Transfer pricing regulations are subject to frequent changes, and tax authorities may update their guidelines and requirements. Keeping abreast of these changes and ensuring compliance can be demanding for companies thus a good transfer pricing consultant in India can support in regular compliance.
4. Documentation Requirements: Most jurisdictions require detailed documentation to support transfer pricing policies. Maintaining comprehensive documentation that satisfies the requirements of various tax authorities can be time-consuming and resource-intensive thus a qualified transfer pricing consultant in India can help ease the process.
5. Identification of Comparable Transactions: Finding truly comparable transactions for benchmarking purposes is often a significant challenge. Differences in industry practices, economic conditions, and the availability of reliable data can complicate the identification of suitable comparables.
6. Economic Downturns and Financial Distress: Economic downturns or financial distress within a multinational group can complicate transfer pricing. Companies may face difficulties in justifying intercompany transactions or maintaining profit margins consistent with their transfer pricing policies.
7. Intangibles and Intellectual Property: The valuation and pricing of intangibles, such as intellectual property, pose specific challenges. Determining the fair value of intangibles and allocating income appropriately among related entities can be subjective and prone to interpretation.
8. Advance Pricing Agreements (APAs): While APAs provide certainty and help mitigate transfer pricing risks, negotiating and implementing APAs can be time-consuming and resource-intensive. Furthermore, APAs are not available in all jurisdictions, limiting their effectiveness.
9. Data and Technology Challenges: Managing and analyzing large volumes of data for transfer pricing purposes can be challenging. Companies need sophisticated data management and analysis tools to comply with transfer pricing requirements effectively.
10. Increased Scrutiny from Tax Authorities: Transfer pricing is under increasing scrutiny from tax authorities globally. Companies may face more frequent audits, and tax authorities may challenge transfer pricing policies, leading to disputes and additional compliance burdens.
11. Intercompany Services: Determining the appropriate pricing for intercompany services, such as management fees or shared services, is a common challenge. Defining the value of these services and establishing an arm’s length price can be subjective.

Addressing these challenges requires a strategic and proactive approach to transfer pricing management. Many multinational companies engage specialized transfer pricing consultants, use advanced technology for data analysis, and seek legal and tax advice to navigate the complexities of transfer pricing regulations and mitigate risks. Anbac Advisors has a qualified team of transfer pricing consultants in Delhi, Bangalore, Mumbai, Hyderabad as well as other regions of India.

We are one of the leading transfer pricing consultants in India with over 8 years of experience of serving a large number of indian and multinational companies in areas related to International Taxation, double tax advisory, corporate advisory, legal structuring.