Transfer Pricing

• 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 render services to/receive services from affiliates free of charge?
• 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 SGA. 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.

• 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. SGA. Provides a range of services such as transfer pricing audit management and assistance in handling competent authority negotiations.
• Managing_Risk :SGA assists companies in preparing a defense 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.
  
• IntegratedTaxPlanning: SGA specializes 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.