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End-to-End Transfer Pricing, BEPS & International Tax Solutions
TP Structuring & Advisory
- Advising on group structuring and transactional pricing
- Conducting value chain analysis and segmenting P&Ls
- Designing and implementing operational TP models
- Reviewing an array of transactions – goods, services, financing, intangibles
- Supporting economic, secondary, and corresponding adjustments
Benchmarking & Policy Setting
- Conducting local, regional, and global benchmarking analyses
- Drafting and reviewing inter-company agreements
- Preparing group-level TP policy and implementation manual
- Reviewing benchmarking reports and advising strategically
BEPS & International Taxation
- Group level Pillar 2 impact assessment and compliances
- CbCR risk mapping and disclosure strategy
- IP structuring and DEMPE functional analysis
- Advising on WHT
- PE risk review and profit attribution
- Analyzing thin capitalization, POEM, and controlled transaction exposure
TP Technology & Digital Enablement
- TP Tech Platform for three-tier documentation, Pillar 2 and disputes management
- Operational TP automation using tech platforms
- TP data analytics for transaction monitoring
- Leveraging AI for drafting TP policies and compliance documentation
Global TP Compliance
- Preparing Local Files, Master Files, and Country-by-Country Reports
- Addressing disclosures and group-level TP compliance
- Preparing comfort letters/memos for statutory auditors
- Supporting FIN 48 and provisioning reviews for multinational enterprises
Dispute Resolution
- Performing TP diagnostic reviews and risk assessments
- Assisting with TP due diligence and strategic audits
- APA and MAP support and strategy advisory
- Managing Safe Harbour applications and renewals
Tax Controversy Management
- Representing clients in TP audits and scrutiny assessments
- Drafting TP submissions
- Advising on litigation strategies and legal precedent analysis
- Conducting cost-benefit reviews of litigation vs. dispute prevention/resolution
- Reviewing adjustments and provisioning for uncertain tax positions
One-stop TP Solution Provider
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