Transfer Pricing

Multinational organizations and other large businesses often operate in an environment of unprecedented complexity. In the last couple of decades, the volume and variety of inter-company transactions have increased dramatically. Keeping pace with this, transfer pricing regulations have evolved continuously and at the same time, enforcement activities have also increased worldwide. All of this has made transfer pricing a leading risk management issue for global businesses.

Xcelentra, along with its associates in different countries, regularly assists companies in managing and reducing such risks. Xcelentra assists companies by aligning practical transfer pricing solutions with their overall global business operations and objectives. We also assist clients with strategic documentation to support their transfer pricing practices, and we help our clients in resolving disputes efficiently.

Xcelentra takes an integrated approach, resolving transfer pricing disputes and regularly achieves positive and successful results for its clients.

Our wide range of services includes

The volume of related-party transactions at multinational businesses is constantly on the rise. This coupled with increased tax authority collaboration across borders presents both risks and opportunities. Xcelentra provides practical solutions which enable companies to strategically approach transfer pricing documentation requirements. This helps global businesses in achieving their operational and international tax planning objectives.
Transfer pricing presents many legal, operational, and tax related challenges. This creates a massive business risk and may require the company’s top management to successfully defend a transfer pricing examination. APAs allow taxpayers to proactively reduce this risk via advance agreements on their transfer pricing methods with one or more tax authorities. Xcelentra regularly assists its client companies in managing their transfer pricing issues – particularly the risk of double taxation – on a prospective basis via such APAs.
During a transfer pricing examination, clients often end up making critical mistakes while responding to initial tax authority inquiries and interviews. The most effective and efficient defense requires the early involvement of an experienced advisor. Such advisors should have experience of successful resolution of examinations at all possible levels of the process, ranging from proposed adjustments by field agents, to Advance Pricing Agreements, administrative appeals, litigation and the MPA/CA process. Xcelentra takes an integrated approach to resolving transfer pricing disputes and has achieved positive outcomes for its clients regularly.
The global economic environment is characterized by continuous changes in technology, best practices and processes, and legislative changes. At Xcelentra, we believe that due to these continuous and rapid changes, periodic assessment of a multinational company’s global business model is a critical exercise. Business Model Optimization (BMO) is the process of balancing the demands of operations and tax laws and integrating them into a company’s business model. This helps ensure that taxes have the lowest possible impact on a company’s bottom line. This enables businesses to achieve the maximum possible profitability. At Xcelentra, we provide high quality, customised tax and BMO services that focus on helping our client companies in integrating operational and tax planning in a scalable and sustainable manner. This enables businesses to achieve the greatest possible tax efficiency, without compromising on tax compliance.