Transfer Pricing & APA

Transfer Pricing

Over the past decade, Indian economy has witnessed a humungous growth in International and Domestic trade. Therefore, the need to devise a practical Transfer pricing (‘TP’) solution for International and Domestic transactions has assumed great significance.This Legislation affects all areas of business operations like supply-chain, trade margins, etc, and resultantly has a major impact on the bottom line. Our team possesses the expertise in International Transfer Pricing and Specific Domestic Transaction (‘SDT’) for addressing the need of business to effectively conduct a study, work out a TP methodology both from an international and domestic perspective with strategic documentation for justifying pricing mechanism and minimize litigation. We also represent Clients in transfer pricing litigations, across all Appellate and Writ Courts.

Advance Pricing Agreement (APA)

Transfer pricing law and compliances, have drastically increased in their scope and application; thereby increasing compliance costs for most corporate assesses. Under such circumstances, an Advance Pricing Agreement (APA) is an agreement entered into in advance between the income tax authorities and an Assessee to set a particular arm’s length price for the purpose of transfer pricing assessment, irrespective of actual transaction price. This helps to simplify the tedious task of transfer pricing assessments to a great extent and a proper implementation of APAs for a cross section of industries enables to reverse the trend of ever increasing adjustments (both in quantum and number). SM & Associates team offers advisory services on APA documentation, filling, representation and negotiation with tax authorities in this regard.