JGarg Transfer Pricing Services & Capabilities 2016
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Transfer pricing brochure of JGarg Economic Advisors Pvt. Ltd., New Delhi, India. Regards Gaurav Garg www.jgarg.com
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3901799 transfer-pricing
Transfer pricing refers to the prices charged for goods and services transferred between subunits of the same organization. There are several methods for determining transfer prices, including market-based prices, cost-based prices, and negotiated prices. Multinational companies use transfer pricing to minimize taxes, duties, and tariffs paid across different jurisdictions. When goods are transferred between subunits in different countries with varying tax rates, the transfer price should be chosen to maximize the overall tax savings for the organization.
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Transfer Pricing
ASAC offers a comprehensive range of transfer pricing services to help multinational companies optimize their transfer pricing policies and navigate changes in international tax regulations. Their services include developing transfer pricing documentation, benchmarking analyses, supply chain management, and assistance with tax audits and disputes. They aim to deliver value that contributes to clients' bottom lines by improving pricing efficiency, reducing penalties, and minimizing compliance costs.
Transfer Pricing and BEPS
Prices charged between associated enterprises established in different countries may not reflect an independent market price, which is called transfer pricing. This is a major concern for tax authorities, who worry that MNEs may set transfer prices on cross-border transactions to reduce taxable profits in their jurisdiction. This has led to the rise of transfer pricing regulations and enforcement, making transfer pricing a major tax compliance issue. While there were too much gaps and frictions in the combination of domestic tax rules and the OECD guidelines, the OECD issued its BEPS Action Plan.
Transfer pricing a bird's eye view
Transfer pricing is covered under Chapter X of Income Tax Act, 1961. It is a vast subject. In this presentation, we have included a bird's eye view to the introduction of transfer pricing, why transfer pricing concept was required and how we can apply transfer pricing. A brief understanding of every method is provided in this presentation. Each and every method or concept is being clarified with the help of various examples for ease of understanding. This presentation targets an beginer to the concept of transfer pricing.
Transfer pricing How MNC's use it
Explains about the transfer pricing, how its been used by MNC's to avoid taxes and get benefited more.
Overview of transfer pricing
Controlled
transaction
A Inc.
(USA)
Uncontrolled
transaction
B Inc.
(USA)
$10
A Ltd.
(India)
C Ltd.
(India)
GM 20%
$8
Customers
Customers
1) Transfer pricing refers to the prices charged for transactions between associated enterprises, and aims to ensure they are consistent with prices charged between independent parties (arm's length principle).
2) India introduced transfer pricing provisions to prevent profit shifting by multinational enterprises from high tax to low tax jurisdictions.
3) The key concepts are arm's length price, transfer price, uncontrolled transactions, controlled transactions
Transfer pricing concept and practice
This is an attempt to explain the broad concept of and rationale behind Transfer Pricing Regulations. Also gives a high level view of the scheme of Indian Transfer Pricing Regulations as on date. Points out the TP controversies in India. Above all gives a well spirited guidance on dealing with TP in India.
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This document provides an overview of Talent Forum, a non-profit organization in South Asia focused on developing a knowledge-based economy. Its key activities include:
- Providing free career counseling, interview coaching, and other services to students and professionals through its Community & Campus Engagement Division.
- Hosting seminars, knowledge sharing sessions, and publications with seasoned professionals through its Expert Engagement Division.
- Offering commercial HR consulting services like organizational restructuring, performance management, and professional search through its Commercial Division.
- Engaging a network of global knowledge partners and influencers from various industries and geographies to share expertise.
Talent Forum.pptx
This document provides an overview of Talent Forum, a non-profit organization in South Asia focused on developing a knowledge-based economy. Its key activities include:
- Providing free career counseling, interview coaching, and other services to students and professionals through its Community & Campus Engagement Division.
- Hosting seminars, knowledge sharing sessions, and publications with seasoned professionals through its Expert Engagement Division.
- Offering commercial HR consulting services like organizational restructuring, performance management, and professional search through its Commercial Division.
- Engaging a network of global knowledge partners and influencers from various industries and geographies to share expertise.
Bvent Profile
BVENT Advisors is a business advisory firm providing accounting, taxation, compliance, and outsourcing services. It has a team of qualified professionals like CAs, CSs, and lawyers. The company aims to be the preferred provider for SMEs by helping clients strengthen operations and finances. BVENT offers services including tax filing, registrations, accounting, legal services, and GST advisory to clients in various industries. It has experienced associates and processes to ensure quality delivery of services at reduced costs compared to in-house resources.
PathwayPartners Company Info - Nov 2016
Pathway Partners Inc. is a boutique consulting company specializing in the insurance industry. They provide broker and carrier clients with consulting services focused on business processes, industry trends, operational optimization, and solution implementation. Their services include performance audits, benchmarking, business process reviews, and guiding clients through selecting and implementing new systems and solutions. They aim to help clients improve efficiency, eliminate duplication, and maximize value.
BKP 360
Bookkeeping 360 is an Indian finance and accounting outsourcing startup based in Mumbai. It provides traditional accounting services like accounts receivable, accounts payable, payroll, and financial reporting, as well as newer services like business process improvement and performance measurement. The company utilizes a combination of accounting expertise and technology to deliver comprehensive solutions. It focuses on quality over quantity and aims to provide superior customer service by solving clients' long-term business problems. The leadership team has extensive experience in finance, auditing, and private equity.
Yagna overview may 2020
The document discusses common problems faced by SMEs such as low capacity, poor profits and cash flow, delayed customer deliveries, long lead times, material shortages, and high inventory. It presents a vicious cycle diagram to illustrate the interconnected causes and effects. The document then evaluates how the Theory of Constraints (TOC) approach can help convert untapped capacity into cash flow in a short period of time without additional investment by focusing on constraints. Case studies are presented showing how YAGNA has helped various clients significantly improve key metrics like throughput, inventory turns, lead times, and on-time delivery performance within months.
Helpline group qatar
Is the pioneers in the field of Company Registration in Qatar service sector with more than 25 years of excellence and professional experience.
Greenough Group Company Overview 04.19.2015
This document summarizes the services provided by Greenough Consulting Group (GCG), a firm that offers finance, accounting, and human resources services. GCG works with start-ups, midmarket companies, and private equity firms. They serve as interim CFOs, controllers, and administrators. GCG leverages expertise across industries to help clients address financial and business challenges. They pride themselves on dedicated client service and act with integrity. GCG's services include financial consulting, HR support, interim executive roles, and international services. They work with various industries and are trusted by over 500 companies and 100 private equity firms.
RSva-Credentials-2021-22-October-2021.pdf
RSva Solutions Pvt Ltd is a team of committed professionals providing financial and business advisory solutions. Their objective is to leverage knowledge and expertise to support clients. Their core values include integrity, respect, excellence, learning, collaboration, and humility. The company was founded by Rajeshree Sabnavis, who has over 25 years of experience in tax, transactions, and transfer pricing. The core team also includes Ritika Agarwal, Disha Jain, Monisha Patel, and Mansi Sanghavi who provide services across tax advisory, compliance, mergers and acquisitions, and financial advisory. Ravikant Sabnavis is an operating advisor with experience building businesses across diverse sectors.
Staring in Business in IT
India has biggest and definitive platform for doing business in India. If you think starting up business in IT, Setting up IT/Software Company and many more.
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J garg india union budget 2014
The document summarizes key proposals in India's 2014 corporate tax legislation. It discusses clarifications that corporate social responsibility (CSR) expenditures will not be tax deductible. It also discusses proposals to extend the time limit for depositing tax deducted at source and to limit tax disallowance to 30% for expenses where full TDS was not deposited. Additionally, it outlines incentives for manufacturing companies investing over Rs. 25 crores, as well as extensions of sunset dates for power sector tax breaks and incentives for semiconductor manufacturing. Proposals regarding transfer pricing documentation and deemed transactions between residents and non-residents are also covered.
India's Domestic Transfer Pricing
This document summarizes key aspects of domestic transfer pricing in India. It discusses the applicability of transfer pricing provisions to specified domestic transactions (SDTs) if the aggregate value exceeds Rs. 5 crores. It outlines the compliance requirements including determining the arm's length price using specified methods and maintaining documentation. The five acceptable transfer pricing methods - Comparable Uncontrolled Price (CUP) method, Resale Price Method (RPM), Cost Plus Method (CPM), Profit Split Method (PSM), and Transactional Net Margin Method (TNMM) - are also briefly described.
JGarg Knowledge Flash April 2012
This document provides a summary of 3 key items:
1. GAAR may be implemented after several months or in FY 2013-14 and only apply to transactions over INR 15 crore to soothe investors.
2. India and Switzerland signed a treaty to share information on Indian citizens with Swiss bank accounts to help India get details even without limited information.
3. RBI allowed higher cost refinancing of existing external commercial borrowings and approved working capital ECB for civil aviation under certain conditions.
Concept Of Cfc..
This document discusses the concept of controlled foreign companies (CFC) and CFC regulations. It defines a CFC as a foreign company controlled by residents of another state. The goal of CFC rules is to tax domestic companies on profits allocated to foreign subsidiaries in low-tax countries. The document outlines different approaches countries take to CFC rules, exemptions, and how CFC rules interact with tax treaties. It provides examples of CFC regulations in countries like Australia, Canada, France, Germany, and the US. It concludes by briefly discussing other anti-avoidance rules countries have implemented.
Article 14 & 15 Of OCED MC
The document summarizes key aspects of Article 15 of the OECD Model Tax Convention related to the taxation of dependent personal services. It discusses that salaries derived by a resident of one state for employment exercised in another state may be taxed by the other state. However, such income remains taxable only in the state of residence if the individual's presence in the other state does not exceed 183 days and certain other conditions are met. The document also discusses the meaning of employer and aspects related to computation of number of days spent in a state.
Intangible Asset, Inter-Company Services and Transfer Pricing
This document summarizes key learnings from a recent international tax and transfer pricing conference. It discusses trends in transfer pricing additions by the Indian government and common reasons for such additions like recommending higher margins or disallowing fees paid to associated enterprises. It also presents two case studies, one involving royalty payments for a technical know-how agreement and the other involving royalty payments for a trademark. The document then covers steps to properly identify, value and document intangible assets for transfer pricing. Finally, it discusses issues around intercompany services and pricing them on a cost-plus basis.
Indian TP Regulations - II
The document discusses the compliance requirements and penalties related to maintaining documentation for international transactions under Indian tax law. It provides details on the types of documents that must be kept, including enterprise-wide documents, transaction-specific documents, and computation-related documents. It also outlines the penalties for failure to maintain documentation or report international transactions, as well as the process for draft tax orders and advance pricing agreements.
Indian TP Regulations Part I
The document summarizes key aspects of Indian transfer pricing regulations including:
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May’s reports showed signs of continued economic growth, said Sam Millette, director, fixed income, in his latest Economic Risk Factor Update.
For more market updates, subscribe to The Independent Market Observer at https://blog.commonwealth.com/independent-market-observer.
Does teamwork really matter? Looking beyond the job posting to understand lab...
Does teamwork really matter? Looking beyond the job posting to understand lab...Labour Market Information Council | Conseil de l’information sur le marché du travail
Vicinity Jobs’ data includes more than three million 2023 OJPs and thousands of skills. Most skills appear in less than 0.02% of job postings, so most postings rely on a small subset of commonly used terms, like teamwork.
Laura Adkins-Hackett, Economist, LMIC, and Sukriti Trehan, Data Scientist, LMIC, presented their research exploring trends in the skills listed in OJPs to develop a deeper understanding of in-demand skills. This research project uses pointwise mutual information and other methods to extract more information about common skills from the relationships between skills, occupations and regions.Governor Olli Rehn: Inflation down and recovery supported by interest rate cu...
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Ending stagnation: How to boost prosperity across Scotland
A toxic combination of 15 years of low growth, and four decades of high inequality, has left Britain poorer and falling behind its peers. Productivity growth is weak and public investment is low, while wages today are no higher than they were before the financial crisis. Britain needs a new economic strategy to lift itself out of stagnation.
Scotland is in many ways a microcosm of this challenge. It has become a hub for creative industries, is home to several world-class universities and a thriving community of businesses – strengths that need to be harness and leveraged. But it also has high levels of deprivation, with homelessness reaching a record high and nearly half a million people living in very deep poverty last year. Scotland won’t be truly thriving unless it finds ways to ensure that all its inhabitants benefit from growth and investment. This is the central challenge facing policy makers both in Holyrood and Westminster.
What should a new national economic strategy for Scotland include? What would the pursuit of stronger economic growth mean for local, national and UK-wide policy makers? How will economic change affect the jobs we do, the places we live and the businesses we work for? And what are the prospects for cities like Glasgow, and nations like Scotland, in rising to these challenges?
在线办理(UMASS毕业证书)马萨诸塞大学阿默斯特分校毕业证完成信一模一样
学校原件一模一样【微信：741003700 】《(UMASS毕业证书)马萨诸塞大学阿默斯特分校毕业证》【微信：741003700 】学位证，留信认证（真实可查，永久存档）原件一模一样纸张工艺/offer、雅思、外壳等材料/诚信可靠,可直接看成品样本，帮您解决无法毕业带来的各种难题！外壳，原版制作，诚信可靠，可直接看成品样本。行业标杆！精益求精，诚心合作，真诚制作！多年品质 ,按需精细制作，24小时接单,全套进口原装设备。十五年致力于帮助留学生解决难题，包您满意。
本公司拥有海外各大学样板无数，能完美还原。
1:1完美还原海外各大学毕业材料上的工艺：水印，阴影底纹，钢印LOGO烫金烫银，LOGO烫金烫银复合重叠。文字图案浮雕、激光镭射、紫外荧光、温感、复印防伪等防伪工艺。材料咨询办理、认证咨询办理请加学历顾问Q/微741003700
【主营项目】
一.毕业证【q微741003700】成绩单、使馆认证、教育部认证、雅思托福成绩单、学生卡等！
二.真实使馆公证(即留学回国人员证明,不成功不收费)
三.真实教育部学历学位认证（教育部存档！教育部留服网站永久可查）
四.办理各国各大学文凭(一对一专业服务,可全程监控跟踪进度)
如果您处于以下几种情况：
◇在校期间，因各种原因未能顺利毕业……拿不到官方毕业证【q/微741003700】
◇面对父母的压力，希望尽快拿到；
◇不清楚认证流程以及材料该如何准备；
◇回国时间很长，忘记办理；
◇回国马上就要找工作，办给用人单位看；
◇企事业单位必须要求办理的
◇需要报考公务员、购买免税车、落转户口
◇申请留学生创业基金
留信网认证的作用:
1:该专业认证可证明留学生真实身份
2:同时对留学生所学专业登记给予评定
3:国家专业人才认证中心颁发入库证书
4:这个认证书并且可以归档倒地方
5:凡事获得留信网入网的信息将会逐步更新到个人身份内，将在公安局网内查询个人身份证信息后，同步读取人才网入库信息
6:个人职称评审加20分
7:个人信誉贷款加10分
8:在国家人才网主办的国家网络招聘大会中纳入资料，供国家高端企业选择人才
快速制作美国迈阿密大学牛津分校毕业证文凭证书英文原版一模一样
原版一模一样【微信：741003700 】【美国迈阿密大学牛津分校毕业证文凭证书】【微信：741003700 】学位证，留信认证（真实可查，永久存档）offer、雅思、外壳等材料/诚信可靠,可直接看成品样本，帮您解决无法毕业带来的各种难题！外壳，原版制作，诚信可靠，可直接看成品样本。行业标杆！精益求精，诚心合作，真诚制作！多年品质 ,按需精细制作，24小时接单,全套进口原装设备。十五年致力于帮助留学生解决难题，包您满意。
本公司拥有海外各大学样板无数，能完美还原海外各大学 Bachelor Diploma degree, Master Degree Diploma
1:1完美还原海外各大学毕业材料上的工艺：水印，阴影底纹，钢印LOGO烫金烫银，LOGO烫金烫银复合重叠。文字图案浮雕、激光镭射、紫外荧光、温感、复印防伪等防伪工艺。材料咨询办理、认证咨询办理请加学历顾问Q/微741003700
留信网认证的作用:
1:该专业认证可证明留学生真实身份
2:同时对留学生所学专业登记给予评定
3:国家专业人才认证中心颁发入库证书
4:这个认证书并且可以归档倒地方
5:凡事获得留信网入网的信息将会逐步更新到个人身份内，将在公安局网内查询个人身份证信息后，同步读取人才网入库信息
6:个人职称评审加20分
7:个人信誉贷款加10分
8:在国家人才网主办的国家网络招聘大会中纳入资料，供国家高端企业选择人才
How Non-Banking Financial Companies Empower Startups With Venture Debt Financing
How Non-Banking Financial Companies Empower Startups With Venture Debt Financing
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Falcon stands out as a top-tier P2P Invoice Discounting platform in India, bridging esteemed blue-chip companies and eager investors. Our goal is to transform the investment landscape in India by establishing a comprehensive destination for borrowers and investors with diverse profiles and needs, all while minimizing risk. What sets Falcon apart is the elimination of intermediaries such as commercial banks and depository institutions, allowing investors to enjoy higher yields.
Independent Study - College of Wooster Research (2023-2024)
"Does Foreign Direct Investment Negatively Affect Preservation of Culture in the Global South? Case Studies in Thailand and Cambodia."
Do elements of globalization, such as Foreign Direct Investment (FDI), negatively affect the ability of countries in the Global South to preserve their culture? This research aims to answer this question by employing a cross-sectional comparative case study analysis utilizing methods of difference. Thailand and Cambodia are compared as they are in the same region and have a similar culture. The metric of difference between Thailand and Cambodia is their ability to preserve their culture. This ability is operationalized by their respective attitudes towards FDI; Thailand imposes stringent regulations and limitations on FDI while Cambodia does not hesitate to accept most FDI and imposes fewer limitations. The evidence from this study suggests that FDI from globally influential countries with high gross domestic products (GDPs) (e.g. China, U.S.) challenges the ability of countries with lower GDPs (e.g. Cambodia) to protect their culture. Furthermore, the ability, or lack thereof, of the receiving countries to protect their culture is amplified by the existence and implementation of restrictive FDI policies imposed by their governments.
My study abroad in Bali, Indonesia, inspired this research topic as I noticed how globalization is changing the culture of its people. I learned their language and way of life which helped me understand the beauty and importance of cultural preservation. I believe we could all benefit from learning new perspectives as they could help us ideate solutions to contemporary issues and empathize with others.
Unlock Your Potential with NCVT MIS.pptx
The NCVT MIS Certificate, issued by the National Council for Vocational Training (NCVT), is a crucial credential for skill development in India. Recognized nationwide, it verifies vocational training across diverse trades, enhancing employment prospects, standardizing training quality, and promoting self-employment. This certification is integral to India's growing labor force, fostering skill development and economic growth.
Seeman_Fiintouch_LLP_Newsletter_Jun_2024.pdf
The Impact of the 2024 Indian
Election Beyond Borders
01. Investment Gyan
02. Market Update
03. Inspiration investment story
falcon-invoice-discounting-a-premier-investment-platform-for-superior-returns...
falcon-invoice-discounting-a-premier-investment-platform-for-superior-returns...Falcon Invoice Discounting
Falcon stands out as a top-tier P2P Invoice Discounting platform in India, bridging esteemed blue-chip companies and eager investors. Our goal is to transform the investment landscape in India by establishing a comprehensive destination for borrowers and investors with diverse profiles and needs, all while minimizing risk. What sets Falcon apart is the elimination of intermediaries such as commercial banks and depository institutions, allowing investors to enjoy higher yields.一比一原版美国新罕布什尔大学(unh)毕业证学历认证真实可查
永久可查学历认证【微信：A575476】【美国新罕布什尔大学(unh)毕业证成绩单Offer】【微信：A575476】（留信学历认证永久存档查询）采用学校原版纸张、特殊工艺完全按照原版一比一制作（包括：隐形水印，阴影底纹，钢印LOGO烫金烫银，LOGO烫金烫银复合重叠，文字图案浮雕，激光镭射，紫外荧光，温感，复印防伪）行业标杆！精益求精，诚心合作，真诚制作！多年品质 ,按需精细制作，24小时接单,全套进口原装设备，十五年致力于帮助留学生解决难题，业务范围有加拿大、英国、澳洲、韩国、美国、新加坡，新西兰等学历材料，包您满意。
【业务选择办理准则】
一、工作未确定，回国需先给父母、亲戚朋友看下文凭的情况，办理一份就读学校的毕业证【微信：A575476】文凭即可
二、回国进私企、外企、自己做生意的情况，这些单位是不查询毕业证真伪的，而且国内没有渠道去查询国外文凭的真假，也不需要提供真实教育部认证。鉴于此，办理一份毕业证【微信：A575476】即可
三、进国企，银行，事业单位，考公务员等等，这些单位是必需要提供真实教育部认证的，办理教育部认证所需资料众多且烦琐，所有材料您都必须提供原件，我们凭借丰富的经验，快捷的绿色通道帮您快速整合材料，让您少走弯路。
留信网认证的作用:
1:该专业认证可证明留学生真实身份
2:同时对留学生所学专业登记给予评定
3:国家专业人才认证中心颁发入库证书
4:这个认证书并且可以归档倒地方
5:凡事获得留信网入网的信息将会逐步更新到个人身份内，将在公安局网内查询个人身份证信息后，同步读取人才网入库信息
6:个人职称评审加20分
7:个人信誉贷款加10分
8:在国家人才网主办的国家网络招聘大会中纳入资料，供国家高端企业选择人才
→ 【关于价格问题（保证一手价格）
我们所定的价格是非常合理的，而且我们现在做得单子大多数都是代理和回头客户介绍的所以一般现在有新的单子 我给客户的都是第一手的代理价格，因为我想坦诚对待大家 不想跟大家在价格方面浪费时间
对于老客户或者被老客户介绍过来的朋友，我们都会适当给一些优惠。
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Using Online job postings and survey data to understand labour market trends
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[4:55 p.m.] Bryan Oates
OJPs are becoming a critical resource for policy-makers and researchers who study the labour market. LMIC continues to work with Vicinity Jobs’ data on OJPs, which can be explored in our Canadian Job Trends Dashboard. Valuable insights have been gained through our analysis of OJP data, including LMIC research lead
Suzanne Spiteri’s recent report on improving the quality and accessibility of job postings to reduce employment barriers for neurodivergent people.
Decoding job postings: Improving accessibility for neurodivergent job seekers
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Using Online job postings and survey data to understand labour market trends
Using Online job postings and survey data to understand labour market trends
JGarg Transfer Pricing Services & Capabilities 2016
- 1. Transfer Pricing Services & Capabilities 2016 1JGarg Economic Advisors Pvt. Ltd.
- 2. • About JGarg • Transfer Pricing Services • Transfer Pricing Capabilities • Contact Index JGarg Economic Advisors Pvt. Ltd.
- 3. • Started by an ex-Big4, JGarg Eco o ic Advisors Pvt. Ltd. JGarg is a iche consulting firm in the area of FDI, Tax & Transfer Pricing. • For last 7 years, JGarg is assisting corporate taxpayers and their tax consultants in successfully dealing with various tax and transfer pricing issues. • JGarg is based out of New Delhi and is very well networked with professional firms in India and outside India. • JGarg team comprises of qualified professionals dedicated to find solution and add value to clients through their expertise and experience in the subject matter. About JGarg JGarg Economic Advisors Pvt. Ltd.
- 4. JGarg renders following services in the area of transfer pricing: • Developing global transfer pricing policy • Global benchmarking study • Transfer pricing documentation – Master file – Local or country file – Country by country regulation • Litigation support • Assistance in APAs Transfer Pricing Services JGarg Economic Advisors Pvt. Ltd.
- 5. Transfer Pricing Capabilities Practice Leader • Headed by CA.Gaurav Garg • Gaurav has got more than 11 years of full time exposure in dealing with various transfer pricing issues • Before starting JGarg, he was part of one of the Big4 s transfer pricing team • He is regular speaker on the subject and has delivered more than 150 lectures on the subject Databases •ACE TP: Online database of more than 38,000 companies •Capitaline Plus: Digital database of 35,000 listed and unlisted companies in India •Prowess: Online database of more than 27,000 Indian companies •OneSoure TP Documenter: Database of more than 70,000 public traded companies and over two million privately-held companies from over 110 countries Team • Dedicated transfer pricing team • Comprises of in-house Chartered Accountants, MBAs and Lawyers • Experience of serving clients in different industries including Auto Ancillary, BPO/KPO, Consumer products, Engineering, FMCG, Heavy Machinery, ITeS, Management Consulting, Oil & Gas, Pipes etc
- 6. JGarg Economic Advisors Pvt. Ltd. 707, Pearl Best Heights II, Netaji Subhash Place, Pitam Pura Delhi - 110034 (E): gaurav@jgarg.com (L): 011- 40775501 (M): +91 9899994934 (W): www.jgarg.com Contact JGarg Economic Advisors Pvt. Ltd.