Transfer Pricing Services
Transfer Pricing refers to the pricing of transactions between related entities of the same group, located in different tax jurisdictions. Tax authorities across the world, including India, closely scrutinize these transactions to prevent tax base erosion and profit shifting.
Why Choose Garuna Consultancy Services?
- Strong expertise in international taxation and transfer pricing laws.
- Extensive experience across industries like IT, Manufacturing, FMCG, Pharma, and Services.
- Practical and tailored solutions to balance tax efficiency with regulatory compliance.
- Trusted by multinational groups for benchmarking, compliance, and dispute management.
Key Aspects of Transfer Pricing
Arm’s Length Principle (ALP)
- Ensuring intra-group transactions are priced as if they were between independent enterprises.
Transfer Pricing Documentation
- Master File, Local File, and Country-by-Country Report (CbCR) as mandated by Indian Income Tax Law.
Methods of Transfer Pricing
- Comparable Uncontrolled Price Method (CUP)
- Resale Price Method (RPM)
- Cost Plus Method (CPM)
- Profit Split Method (PSM)
- Transactional Net Margin Method (TNMM)
Our Transfer Pricing Services
Advisory & Planning
- Designing tax-efficient yet compliant transfer pricing policies.
- Structuring intra-group transactions to minimize risks.
Documentation & Compliance
- Preparing Master File, Local File, and CbCR in line with Indian and OECD requirements.
- Conducting benchmarking studies to justify arm’s length pricing.
Transfer Pricing Audit Support
- Assisting during audits, assessments, and responding to queries from tax authorities.
Advance Pricing Agreements (APA)
- Advisory and representation for bilateral/multilateral APAs with tax authorities to reduce disputes.