Global integration, new business practices and increasing scrutiny of international transactions between associated enterprises challenge multinational corporations in India to find innovative transfer pricing solutions. Indian transfer pricing regulations are applicable to intra-group arrangements which have to be structured having regard to the arm’s length price. Exhaustive documentation and certification requirements coupled with the aggressive approach of the Revenue authorities during audit contribute to transfer pricing planning and compliance becoming a key point of attention.
The International Tax Review rates PwC as India’s leading transfer pricing adviser with the largest and most diversified client base. The Transfer Pricing team of PwC in India comprises a core team of professionals with expertise in diverse areas of Finance, Taxation, Law and Economics. PwC India has established transfer pricing expertise in industries such as automotive, manufacturing, technology, outsourcing, pharma and services. The team includes professionals having rich experience in conducting transfer pricing studies and others who have participated in international tax courses and programs in transfer pricing conducted by the International Bureau of Fiscal Documentation.
How PwC can help:
- High-level diagnostic of a group’s transfer pricing policies, especially in due diligence assignments
- Detailed functional analysis of selected entities and related industry analyses
- Comparables and Benchmarking analysis exercises
- Compliance with local or global documentation sets (in line with the PwC Global Core Documentation® approach)
- Price setting (TP planning) of entities in terms of functions performed and risks assumed
- Structuring of inter company transactions and new business initiatives (using an integrated approach with the Tax and Regulatory team)
- Analysis of tax efficient IP exploitation schemes
- Representation before Revenue authorities for Transfer Pricing audit defence
- Management of international TP projects from an Indian perspective
- Analysis of attribution of profits to Permanent Establishment (PE)
