For any foreign subsidiary in India, transactions with the parent company—whether for management services, royalties, or software development—are under the microscope of Indian Tax Authorities. The Indian Transfer Pricing Code is one of the toughest in the world, requiring strict documentation to prove that your prices are fair (at “Arm’s Length”).
At BusinessSetup.in, we move beyond simple compliance. We help you plan your pricing policies before the first invoice is raised, ensuring that your profit repatriation strategies (Royalties, Dividends, Interest) are tax-efficient and fully compliant with Indian regulations and Global Base Erosion and Profit Shifting (BEPS) norms.
What We Offer
1. Transfer Pricing Compliance (The Mandatory Filings)
Form 3CEB Certification: This is the non-negotiable annual filing for every Indian company that has international transactions with group companies, regardless of the amount. Our team audits your transactions and files this report by the October 31st deadline.
Transfer Pricing Documentation (The “TP Study”): For entities with international transactions exceeding INR 1 Crore, we prepare the comprehensive TP Study Report. This includes:
Functional Analysis (FAR): Documenting the Functions performed, Assets employed, and Risks assumed by the Indian entity.
Benchmarking Analysis: Using premium databases to find comparable Indian companies and establish the “Arm’s Length Price” range to defend your margins.
2. International Tax & Withholding (TDS)
DTAA Benefit Analysis: India has Double Taxation Avoidance Agreements (DTAA) with over 85 countries. We analyze these treaties to help you lower the Withholding Tax (TDS) rates on payments like Royalties, Interest, and Fees for Technical Services (FTS).
Form 15CA & 15CB: Every time you send money out of India (for services or imports), banks require a Chartered Accountant’s certificate. We issue these certificates promptly to ensure your remittances are not blocked by the bank.
Equalization Levy Advisory: We advise on the applicability of the “Google Tax” (Equalization Levy) on digital advertisements and e-commerce supplies provided by non-resident companies.
3. Strategic Pricing & Planning
Inter-Company Agreement Drafting: Tax authorities often look at the substance over the form. We assist in drafting robust Inter-Company Agreements (Management Services, Loan Agreements, Software Development Agreements) that align with your actual conduct and TP policy.
Profit Repatriation Strategy: We help you evaluate the most tax-efficient route to send profits back to your HQ—comparing Dividends, Buyback of Shares, and Royalty payments based on current tax rates.
4. CbCR & Master File (For Large MNCs)
For large multinational groups (Group Revenue > INR 500 Cr), we handle the advanced compliance of filing the Master File (Form 3CEAA) and Country-by-Country Reporting (CbCR) notifications.
Why Choose BusinessSetup.in?
Database Access: We subscribe to the same premium benchmarking databases used by the Big 4, ensuring our “Arm’s Length” analysis holds up during scrutiny.
Litigation-Ready Documentation: We don’t just write reports for today; we write them assuming they will be read by a tax officer 3 years from now. We build your defense file from Day 1.
Global View: We understand that Transfer Pricing is a two-sided coin. We work with your global tax team to ensure the Indian margin fits into your global effective tax rate strategy.