Transfer Pricing

The emerging scene of transfer pricing audits and disputes

While Indian companies investing overseas are continuously developing strategic footholds and meeting the ever-changing market dynamics; multinational companies are facing the heat of the global slowdown. Further, companies are also facing the challenge of meeting the demands of increasingly combative tax authorities and are experiencing a commonality of issues and controversies around the world.

This new environment places a premium on audit and dispute avoidance techniques for which multinationals are required to adopt a complete and holistic approach, which include not only preparation of quality transfer pricing documentation but also sound strategies on tax audits and defense

If this is your situation
  • You need advice on transfer pricing documentation requirements in India or other jurisdictions
  • You need to respond to transfer pricing audit / enquiry from tax authority
  • You need to know whether your internal controls over transfer pricing are sufficient
  • You need advice on transfer pricing implications of existing or proposed international transactions
  • You are interested in “best practices” for managing your worldwide transfer pricing policies and procedures
  • You need to align with your global transfer pricing policy or formulate a local transfer pricing policy
  • You need assistance in constructing effective cross-border strategies and managing global effective tax rate

Our services

At PwC, we view global developments with the perspective of a firm that has maintained a specialist transfer pricing consulting capability with a focus on quality that you expect from the world’s leading professional services firm. Our Global Transfer Pricing Group consists of over 1,600 dedicated specialists with advanced training in economics, accounting, project management and law, including professionals with significant experience gained with tax administrations.

We can advise on and assist in:

Advisory

Our team of professionals can advise on the transfer pricing implications of existing or proposed international transactions, and assist in providing a framework for creating a transfer pricing policy document. Our experts can assess your existing transfer pricing policies, evaluate potential risks and advise on pragmatic corrective solutions. We can also help you construct effective cross-border strategies and manage your global effective tax rate, including analysis of tax efficient intellectual property exploitation mechanisms and attribution of profits to a permanent establishment

Transfer pricing Documentation

Our transfer pricing team will help you develop local or global transfer pricing documentation and defense files consistent with your needs.

Representation and litigation support

Our team will help you resolve transfer pricing disputes and minimize transfer pricing exposure in future periods. We can coordinate with PwC professionals worldwide to provide effective representation through all phases of controversy resolution. We can also offer advice on the most effective strategy to pursue, and provide technical economics and support in any form.

Due Diligence

We can conduct high level diagnostics of a group’s transfer pricing policies, especially in due diligence assignments.