Transfer Pricing

The enactment of detailed Transfer Pricing Laws in India in 2001 brought the issue of Transfer Pricing to the forefront amongst the various multinational corporations operating in India as well as Indian companies. Transfer Pricing is one of the critical tax issues for growth oriented businesses having international operations wherein substantial senior management’s time and attention is necessary. Irrespective of their size, organizations need an effective and dependable Transfer Pricing policy, which takes into consideration the organization’s overall business strategy and operating structure.

Our Transfer Pricing team with its rich experience and demonstrated capabilities offers comprehensive solutions in areas such as Transfer Pricing Documentation, Transfer Pricing assessments and other value added services such as Benchmarking services, Drafting of Inter-company agreements etc.

What We Do

• Creating Transfer Pricing Documentation – The Transfer Pricing legislation requires that income from International Transactions between Associated Enterprises is computed after considering the arm’s length price. The term “Arm’s-length Price” refers to the price that would be charged for a similar International Transaction between unrelated third parties. The Transfer Pricing Documentation created by VRamaratnam & Company covers the various mandatory requirements under the law and includes:
  • Background of the Company and its Associated Enterprises
  • Functional Analysis to document the Functions, Risks and Assets
  •  Industry Overview
  • Comparability/Benchmarking analysis to prove the Arm’s Length nature deployed of International Transactions entered into between Associated Enterprises
• Representing before Transfer Pricing Authorities – These services include representation before the designated Transfer Pricing Officers/Assessing Officers for Transfer Pricing related matters. The scope of services provided also covers representation before higher authorities like Commissioner of Income Tax etc.
  • Other Value Added Services relating to:
  • Planning Opportunities to achieve lower taxation for the group
  • Assisting clients in Benchmarking vis a vis other players in the same industry
• Drafting of Inter-Company agreements, review of documentation etc..