Transfer Pricing
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We have skilled team of tax practitioners, economists and financial analysts who are masters in their fields. They focus on reducing threats and increasing opportunities to enhance corporate performance through proactive transfer pricing planning. The integration of tax and economics is one of the most important attributes of our transfer pricing capabilities. This unified approach enables us to develop and implement transfer pricing methodologies that are analytically sound, flexible to deal with "real world" situations and fully compliant with the transfer pricing regulations. Further, this approach also ensures a creative and dynamic tax planning process for our clients. As part of our transfer pricing service, we offer advice and assistance in the following areas : Transfer Pricing Planning : Our team helps in evaluation of alternative business structures from a transfer pricing planning perspective in order to optimize allocation of revenues between group entities. Compliance and Documentation : We provide assistance in various aspects of transfer pricing documentation preparation and compliance. A transfer pricing study prepared and supported by sound technical positions significantly reduces the risk of a possible tax contingency. Controversy Resolution : As revenue authorities become more aggressive in applying transfer pricing regulations, disputes are likely to arise. MPA. provides a range of services such as transfer pricing audit management and assistance in handling competent authority negotiations. Managing Risk : MRC assists companies in preparing a defence against possible future inquiries from revenue authorities by assessing the current transfer pricing policies. The potential risks can then be evaluated and if required, appropriate corrective actions can be implemented. Our global controversy solutions and resources enable our clients to confidently address this dynamic issue with confidence. Integrated Tax Planning : MRC specialises in solutions that provide international businesses with an opportunity to comprehensively assess tax position and drive benefits upwards through the company structure. We combine planning, coordination and execution of tax strategies in order to devise flexible solutions that effectively address business changes. Transfer pricing rules under Indian income-tax law require that income from international transactions between associated enterprises be computed at an arm length price. GlobalTransfer Pricing compliance has become all the more relevant after a Supreme Court ruling in a case involving investment bank Morgan Stanley (2007). We are one of the authentic providers of Transfer Pricing Services based in India. Our professionals assist clients in understanding the transactions that are subject to the International Transfer Pricing regulations and analyzing potential pricing methodologies.
Transfer Pricing Services
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Our company has created a niche in the field of rendering Transfer Pricing Services. Our dexterous professionals, having expertise in this domain helping many businesses, to evaluate inter-company transfer pricing policies. We administer this service keeping in mind clients' specific demands. Our services are well known for their promptness and dependability. Moreover, clients can avail our services at very feasible prices. Details : The Indian Union Budget for 2012-13 containing the tax proposals of the Government was presented by the Finance Minister to the Parliament on 16 March, 2012. The Finance Bill, 2012 (FB 2012) that was introduced as part of Budget Proposals includes a number of far reaching amendments to the transfer pricing (TP) provisions of the Indian Tax Law (ITL). FB 2012 proposes to introduce provisions to enable Advance Pricing Agreements (APAs). In addition, the ambit and scope of TP provisions would be widened under the proposals by expanding the definition of “international transaction” to cover business restructuring or reorganization between associated enterprises. A definition of the term “intangible property” is proposed to be introduced. The definition, in addition to covering generally accepted marketing and technology related intangible assets, also includes customer lists, customer relationships and trained and organized work force. The proposals would also extend the applicability of TP provisions to cover specified domestic transactions. FB 2012 also proposes amendments to provisions relating to computation of the arm’s length price (ALP), procedural and penalty provisions relating to TP. A number of the amendments are likely to apply with retrospective effect and could therefore have an impact for prior years as well. Taxpayers would need to assess the impact of the budget proposals on their past and future transactions.
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Transfer Pricing Services
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We are Delhi, India based firm and actively engaged in providing reliable and cost efficient Transfer Pricing Services. Transfer Pricing relates to the price applied to intercompany transactions. We have a team of professionals who hold immense knowledge in this domain and render these services in an optimum manner. They work in coordination with the clients and help them in completing documentation. With us, one can stay assured for timely completion of the assigned task.
Transfer Pricing Services
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As a reliable name, we are engaged in offering trusted and affordable Transfer Pricing Services. Our professionals work efficiently on the principles of dealing and transaction and other relevant transfer pricing regulations pronounced by the prescribed authorities. We are acknowledged for providing hassle-free services and appropriate consultancy in relation to Transfer Pricing. Right from reviewing and evaluation of prices till the completion of the whole process, our professionals will provide you complete guidance to ensure complete satisfaction at your end.
Transfer Pricing Services
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We are offering excellent Transfer Pricing Services that work efficiently on the principles of dealing and transaction and other relevant transfer pricing regulations pronounced by the prescribed authorities. Our Transfer Pricing Services are well known in the domain, owing to its promised accuracy. As our Transfer Pricing Service is highly result-oriented, it has received great admiration from the clients. Assist In : Planning of Transfer Pricing MechanismAdherences and Compliance of Transfer Pricing Regulations and ProvisionsReview and evaluation of Transfer Pricing transactions and representation before the competent authorities in connection with the settlement of disputesDevising conducive tax planning with flexible approach on implementation of methodologies of transfer pricingProviding Pre-Emptive advice on potential threats by reviewing and evaluation of existing policies of an organization
Transfer Pricing Advisory
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As one of the leading advisors to companies, JKC&C understands the need to approach the transfer pricing norms in a customized manner to provide valuable inputs to the management. We are based in Delhi, India and catering to varied needs of corporates in the surrounding regions. Backed by a crew of professionals, we provide comprehensive solutions to meet clients’ functional needs after profiling the exact nature and the extent of the transactions. So, contact us anytime.
Transfer Pricing Certification Services
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Increasing participation of multi-national groups in economic activities in the country has given rise to new and complex issues emerging from transactions entered into between two or more enterprises belonging to the same multi-national group. With a view to provide a detailed statutory framework which can lead to computation of reasonable, fair and equitable profits and tax in India, government has incorporated various acts keeping in mind various aspects in this relation. In the case of multinational enterprises, the Finance Act, 2001 substituted section 92 with a new section and introduced new sections 92A to 92F in the Income-tax Act, relating to computation of income from an international transaction in relation to the arm's length price, meaning of associated enterprise, meaning of information and documents by persons entering into international transactions and definitions of certain expressions occurring in the said section. Under the income-tax provisions, business entity in India who has undertaken any transaction with its non-resident associated enterprises, needs to be file a transfer pricing certificate in prescribed form (Form 3CEB). The certificate is to be issued by a Chartered Accountant certifying the arm’s length pricing of the said transactions. Further the Indian business entity needs to maintain transfer pricing documentation and study to justify its transaction and respective consideration for those transactions. This study contains separate analysis of each type of transactions and its justification regarding arm’s length pricing. What is Section 92? Section 92: As substituted by the Finance Act, 2002 states that any income arising from an international transaction or where the international transaction comprise of only an outgoing, the allowance for such expenses or interest arising from the international transaction shall be determined having regard to the arm's length price. The provisions, however, would not be applicable in a case, where the application of arm's length price results in decrease in the overall tax incidence in India in respect of the parties involved in the international transaction. Arm's length price: In accordance with internationally accepted principles, it has been provided that any income arising from an international transaction or an outgoing like expenses or interest from the international transaction between associated enterprises shall be computed having regard to the arm's length price, which is the price that would be charged in the transaction if it had been entered into by unrelated parties in similar conditions. The arm's length price shall be determined by one of the methods specified in Section 92C in the manner prescribed in Rules 10A to 10C that have been notified vide S.O. 808 E dated 21.8.2001. Arm's length priced can be calculated by one of the specified methods: Comparable uncontrolled price method; Resale price method; Cost plus method; Profit split method or Transactional net margin method. The taxpayer can select the most appropriate method to be applied to any given transaction, but such selection has to be made taking into account the various factors prescribed in the Rules. With a view to allow a degree of flexibility in adopting an arm's length price the proviso to sub-section (2) of section 92C provides that where the most appropriate method results in more than one price, a price which differs from the arithmetical mean by an amount not exceeding five percent of such mean may be taken to be the arm's length price, at the option of the assessee. Ask yourself? Is your company involved in any international transactions with any of its group companies? Does your company engage in any inter-company transactions affecting the operating results? Does your company render services to/receive services from affiliates free of charge? Does your company pay or/ receive charges pertaining to intangibles or cost allocations? Has your company been incurring operating losses over the past few years? Are you a multinational corporation currently structuring your business plan? Are you restructuring global operations as a result of changing global conditions? If your answer is "yes" to one or more of the above questions, your company will in all probability require a transfer pricing review. SERVICES WE OFFER Transfer Pricing Solutions We at Monika Aashish & Co. have skilled team of tax practitioners, economists and financial analysts who are masters in their fields. They focus on reducing threats and increasing opportunities to enhance corporate performance through proactive transfer pricing planning. The integration of tax and economics is one of the most important attributes of our transfer pricing capabilities. This unified approach enables us to develop and implement transfer pricing methodologies that are analytically sound, flexible to deal with "real world" situations and fully compliant with the transfer pricing regulations. Further, this approach also ensures a creative and dynamic tax planning process for our clients. As part of our transfer pricing service, we offer advice and assistance in the following areas: Transfer Pricing Planning Our team helps in evaluation of alternative business structures from a transfer pricing planning perspective in order to optimize allocation of revenues between group entities. Compliance and Documentation We provide assistance in various aspects of transfer pricing documentation preparation and compliance. A transfer pricing study prepared and supported by sound technical positions significantly reduces the risk of a possible tax contingency. Controversy Resolution As revenue authorities become more aggressive in applying transfer pricing regulations, disputes are likely to arise. Monika Aashish & Co. provides a range of services such as transfer pricing audit management and assistance in handling competent authority negotiations. Managing Risk MAC assists companies in preparing a defence against possible future inquiries from revenue authorities by assessing the current transfer pricing policies. The potential risks can then be evaluated and if required, appropriate corrective actions can be implemented. Our global controversy solutions and resources enable our clients to confidently address this dynamic issue with confidence. Integrated Tax Planning MAC specialises in solutions that provide international businesses with an opportunity to comprehensively assess tax position and drive benefits upwards through the company structure. We combine planning, coordination and execution of tax strategies in order to devise flexible solutions that effectively address business changes.
Transfer Pricing Services
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Our range of transfer pricing servicesincludes domestic transfer pricing services and international transfer pricing services. These transfer pricing services are rendered by transfer pricing professionals, who offer comprehensive solutions that are customized as per the specific needs of the clients
Transfer Pricing Services
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We are reckoned for providing the best transfer pricing consulting services in India. Our different sorts of transfer pricing services are simply matchless because of the quality of services offered by us. Our team of dedicated and focused experts works tirelessly to provide quality service. With our global transfer pricing services, we manage your entire price transferring risks world-over. We have helped many big shots of Indian market in transferring their pricing projects domestically and globally as well. We thirst to serve our client better with every single chance we get. Transfer Pricing Mechanism Implementation We provide professional services on spectrum of activities relating to implementation of Transfer Pricing Mechanism with the underlined principles of dealing and transaction at ann's length and other relevant transfer pricing regulations pronounced by the prescribed authorities in this respect. We provide assistance on the followings : Planning of Transfer Pricing Mechanism. Adherences and Compliance of Transfer Pricing Regulations and Provisions. Review and evaluation of Transfer Pricing transactions and representation before the competent authorities in connection with the settlement of disputes. Devising conducive tax planning with flexible approach on implementation of methodologies of transfer pricing. Pre-Emptive advice on potential threats by reviewing and evaluation of existing policies of an organization vis-a-vis current existing legislations to avoid legal and taxation hassles and waste of time and energy.
Transfer Pricing Services
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We provide international tax advisory with respect to a transaction between a resident and a non resident keeping in view Exchange Control Regulations, Corporate Law and Income Tax. We have a team dedicated exclusively for Transfer Pricing.
Transfer Pricing Services
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We are offering Transfer Pricing Services where we are known for working efficiently based on the principles related to dealing, transactions and other significant transfer pricing regulations, which are pronounced by the authorities of Transfer Pricing. Our qualified and well-experienced professionals will help you in giving proper assistance in planning of transfer pricing mechanism, compliance of transfer pricing regulations, evaluation of transfer pricing transactions and represents your firm before the competent authorities in settling disputes. We provide only the best services to our clients at competitive rates.
Transfer Pricing
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