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Transfer Pricing

The enactment of detailed Transfer Pricing Laws in India in 2001 brought the issue of Transfer Pricing to the forefront amongst the various multinational corporations operating in India as well as Indian companies. Transfer Pricing is one of the critical tax issues for growth oriented businesses having international operations wherein substantial senior management’s time and attention is necessary. Irrespective of their size, organizations need an effective and dependable Transfer Pricing policy, which takes into consideration the organization’s overall business strategy and operating structure.


RSM Astute’s Transfer Pricing team with its rich experience and demonstrated capabilities offers comprehensive solutions in areas such as Transfer Pricing Documentation, Transfer Pricing assessments and other value added services such as Benchmarking services, Drafting of Inter-company agreements etc.

What We Do

  • Creating Transfer Pricing Documentation – The Transfer Pricing legislation requires that income from International Transactions between Associated Enterprises is computed after considering the arm’s length price. The term “Arm’s-length Price” refers to the price that would be charged for a similar International Transaction between unrelated third parties. The Transfer Pricing Documentation created by RSM Astute covers the various mandatory requirements under the law and includes:
    • Background of the Company and its Associated Enterprises
    • Functional Analysis to document the Functions, Risks and Assets deployed
    • Industry Overview
    • Comparability/Benchmarking analysis to prove the Arm’s Length nature of International Transactions entered into between Associated Enterprises
  • Representing before Transfer Pricing Authorities – These services include representation before the designated Transfer Pricing Officers/Assessing Officers for Transfer Pricing related matters. The scope of services provided also covers representation before higher authorities like Commissioner of Income Tax etc.
  • Other Value Added Services relating to:
    • Planning Opportunities to achieve lower taxation for the group
    • Assisting clients in Benchmarking vis a vis other players in the same industry
    • Drafting of Inter-Company agreements, review of documentation etc

Advantage RSM Astute

  • Actively servicing a large number of Indian and multinational companies in matters of corporate advisory, taxation and accounting issues across various industries and service verticals.
  • Dedicated team of personnel having expertise in the field of direct taxation, indirect taxation, transfer pricing, foreign exchange regulations, corporate and other commercial regulations.
  • Access to global methodologies, subject expertise and best practices of RSM International.
  • Access to latest and comprehensive Indian and International industry databases
  • RSM Astute Consulting Group (along with its affiliates) together has been ranked as the 5th largest accounting and consulting group in India (International Accounting Bulletin - September 2010).
  • Extensive experience in advisory, taxation and accounting matters across various industries and service verticals.
  • Multi-disciplinary team of professionals comprising of Chartered Accountants, MBAs, Engineers, Company Secretaries, CISA / DISA, Cost Accountants and Law graduates.
  • Indian personnel strength of over 800 people having expertise in diverse fields and Nation wide presence.
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RSM Astute Consulting Group is a member of the RSM network. Each member of the RSM network is an independent accounting and advisory firm each of which practices in its own right. The RSM network is not itself a separate legal entity of any description in any jurisdiction. The RSM network is administered by RSM International Limited, a company registered in England and Wales (company number 4040598) whose registered office is at 11 Old Jewry, London EC2R 8DU. The brand and trademark RSM and other intellectual property rights used by members of the network are owned by RSM International Association, an association governed by article 60 et seq of the Civil Code of Switzerland whose seat is in Zug. © RSM International Association, 2013.
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