Tax is not a cost. It is a value allocation decision.
We design, document, and defend intercompany pricing with OECD rigor, economic precision, and institutional credibility.
Pre-agreed pricing certainty with CBDT and foreign competent authorities.
Functional analysis, risk allocation, and value chain mapping.
Comparable search, method selection, and arm’s length range testing.
Master File, Local File, CbCR, and Form 3CEB compliance.
Policy, intercompany agreements, and global training framework.
Master File, Local File, CbCR, and Form 3CEB under Section 92D.
Unilateral, bilateral, and multilateral APAs with CBDT and foreign CAs.
Mutual Agreement Procedure, arbitration, and ITAT defense.
TNMM, CPM, PSM, and CUP with Prowess, Capitaline, and Bloomberg BNA.
We execute it — with certainty, compliance, and institutional trust.
Begin TP Mandate