The global transfer pricing atmosphere has moved from a controversy borne legislation to a planned and certainty-oriented arena. With the advent of BEPS and several other initiatives taken by the OECD, there has been increased awareness, acceptance and commitment demonstrated by governments in making an attempt to resolve potential transfer pricing controversies. The introduction of Safe Harbour (‘SH’) and Advanced Pricing Agreements (‘APA’) have brought in path-breaking changes in the transfer pricing arena.
The APA and SH involve intense processes pertaining to application preparation, documentation, discussions with the tax authorities and post agreement compliances. The eligibility is determined basis the nature of transaction and the industry to which the business pertains to.
We work closely in association with leading expert tax and legal professionals from our network firms who are specialised in the field and closely co-ordinate the entire process. This association is aimed at bringing subject specific expertise for the benefit of the clientele and in line with our commitment to deliver exceptional client service.