Tax structuring.
Structuring of cross-border arrangements and related-party transactions on an arm's-length basis.
About this service.
Indian entities with international transactions with associated enterprises, and entities with specified domestic transactions exceeding prescribed thresholds.
Structuring for international operations covers inbound and outbound investment vehicles, cross-border financing, and the pricing of related-party transactions between associated enterprises.
Transfer pricing requires that the transfer price reflect the arm's-length principle under sections 92 to 92F of the Income-tax Act, 1961. The firm advises on functional analysis, inter-company transaction design, and BEPS-aligned three-tiered documentation.
Engagements integrate the tax, treaty and transfer-pricing considerations so that the structure is efficient and defensible.
What the engagement covers.
Inbound / outbound investment structuring
Functional analysis and inter-company transaction mapping
Arm's-length pricing methodology selection (TNMM, CUP, Cost-plus, RPM)
Cross-border financing and withholding structuring
BEPS-aligned documentation structuring
Advance Pricing Agreement (APA) planning
Applicable laws and standards.
Other tax services.
Top questions.
The questions clients most often ask about this service. For anything specific to your situation, write to the firm.
The pricing of transactions between associated enterprises on an arm's-length basis, as required under the Income-tax Act.
Sections 92 to 92F of the Income-tax Act and Rules 10A to 10TA.
TNMM, CUP, Cost-plus, Resale Price Method and others, selected through a functional analysis.
An analysis of functions performed, assets employed and risks assumed, used to benchmark related-party pricing.
Yes, above the prescribed threshold, in addition to international transactions.
The Master File, Local File and Country-by-Country Report required under BEPS Action 13.
Yes. Financing arrangements and related withholding are structured as part of the engagement.
An Advance Pricing Agreement that fixes the transfer-pricing methodology in advance with the authorities.
Indian entities transacting with associated enterprises abroad, and groups with cross-border operations.
Structuring designs the arrangement; compliance documents, benchmarks and files it.
Looking for tax structuring support?
Write to the firm to discuss the engagement. Each engagement is scoped through a formal letter, preceded by independence and conflict-of-interest checks.