Looking for a 360-degree holistic approach to meet your entity's transfer pricing and international taxation compliances? SBC, with its rich experience and demonstrated capabilities, believes in providing holistic Transfer Pricing solutions to clients tailored to meet business objectives. With our 360-degree approach, we provide comprehensive Transfer Pricing solutions across judicial forums on all Transfer Pricing matters. To know more, visit https://steadfastconsultants.in/taxation-services/#transferPricing.

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PRICING
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Holistic Transfer Pricing
solutions we offer

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TRANSFER PRICING
COMPLIANCES
Transfer Pricing Documentation(Master file and
Country-by-Country Report)
Accountant's Report - Form No. 3CEB
Transfer Pricing Comfort Letters/Memos for
Statutory Auditors
FIN 48 Assistance

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TRANSFER PRICING
ADVISORY ON
Transfer Pricing Policy & Price Setting
Drafting/Review of Inter-Company Agreements
Benchmarking Analysis
Operational Transfer Pricing
Group Profit & Effective Tax Planning
Secondary Adjustments

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Intangibles-Structuring, Royalty & Licensing rates,
Withholding implications, Agreements
Intra-Group Services, Management Charges, Cost
Contribution Arrangements.
Business Restructurings- Transfer Pricing Implications,
Agreements & Contracts review
General Anti Avoidance Rules (GAAR) implications
Permanent Establishment (PE) Exposure to
existing/proposed transactions
COMPLEX INTER-
COMPANY
TRANSACTIONS
- Planning, Implementation & Compliance support for:

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BEPS Contract Analysis
Value Chain Analysis and Management
Supply Chain Restructuring
Three Tier Documentation support in line with Action 13
IP Structuring /DEMPE analysis in view of Action 8
OECD Pillar 1 & 2 – Readiness, Implementation & Impact
BEPS ADVISORY
- Readiness, Implementation, Impact on International
Tax Structures:

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Assets (tangibles & intangibles) transfer between related
parties
Capital/financial transactions (equity, debt & hybrid
instruments, guarantees)
Mergers & Acquisitions transactions
Valuations for arm's length
determination for Transfer Pricing
purposes:

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First level authorities - Transfer Pricing Officers (TPO)/
Assessing Officers (AO)
Dispute Resolution Panel (DRP)
Appellate authorities - Commissioner of Income Tax
(Appeals) [CIT(A)], Income Tax Appellate Tribunals (ITAT),
High Court, Supreme Court
Penalty, Rectification, Reassessment, Revision, Stay of
demand proceedings.
Transfer Pricing Litigation support &
Representations before

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Cost-Benefit Analysis for decision making
Filing of Applications in prescribed Forms
Representations & Submissions
Application Renewals
APAs – both unilateral & bilateral
Alternate Dispute Resolution Routes -
Advance Pricing Agreement (APA),
Mutual Agreement Procedure (MAP), Safe
Harbour Rules (SHR)

9. https://steadfastconsultants.in/
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