Karmen Yeung is the head of the transfer pricing practice at KPMG. Yeung provides inbound investment structure advice to clients, including corporate holding, structure, financing, the form of investment and fund repatriation strategies. The transfer pricing team helps clients in complying with the BEPS initiatives by conducting BEPS transfer pricing planning, review and documentation projects from a regional and global view. The team has developed technology tools, such as Tax Intelligence Solution (TIS), to advise clients in dealing with transfer pricing compliance.
Chen Lu helped one of the largest international shipping groups in a matter concerning a global BEPS-TP risk assessment and documentation project. The transfer pricing team assisted the client with global BEPS-TP risk assessment and preparation of Country-by-Country Reporting. It also offered a review of the global BEPS-TP defence mechanism of the group, preparing master files and local files globally.
Amit Maheshwari is the head of the transfer pricing practice at Ashok Maheshwary & Associates. The firm provides services including transfer pricing documentation, litigation, APAs, cross-border tax advice and transaction structuring. The firm is a member of Leading Edge Alliance and TPA Global. In 2018, the firm has also become member of TIAG and TAG Law. TIAG is an alliance that has more than 115 accounting firms covering more than 70 countries. TAG Law is an alliance of law firms with 150 member firms based in more than 90 countries.
In the past year, Charu Baweja, Shilpa Bhatia and Amit Maheshwari advised Samvardhana Motherson Group on transfer pricing certification and documentation. The firm used Indian transfer pricing databases to find out comparable companies to the services rendered to the related parties. In addition, the team also used foreign benchmarking in the case of receipt of services.
In 2017, Surabhi Chandra joined the firm as a manager. In 2018, Shikha Jain, Monica Jaiswal and Vipul Jain joined the firm as assistant managers. Shavikesh Goel and Abhipray Basu also joined the firm as a partners.
“They are extremely professional and provide access to an extremely high level knowledge pool. More importantly the partners have a hands-on approach and do not leave everything on the associates, which was a challenge we faced with other firms. However, ever since we have started working with them we haven’t faced any such issues.”
Miliand Kothari is the head of the transfer pricing department at BDO India. The practice includes tax and regulatory and the indirect tax service. The team has professionals across various areas, including corporate tax, international tax, transactional tax, transfer pricing, expatriate tax, goods and services tax, customs and international trade, corporate laws, capital markets and regulatory.
Jiger Saiya and Abhay Kumar assisted a client with transfer pricing advisory. The firm made a determination of arm’s length royalty and provided opinions regarding management fees from a tax, regulatory and transfer pricing perspective. Partho Dasgupta and Niladri Bhattacharyya advised a client on transfer pricing involving intangibles. BDO India reviewed the transfer pricing model duly considering implications under BEPS action plan 8-10.
The firm has expanded by hiring 39 partners and 89 directors and senior staff in 2017 and 2018.
Vishweshwar Mudigonda is the head of the transfer pricing department at Deloitte. The firm provides a wide range of practices, including compliance and documentation, planning and implementation, controversy management, global documentation, MAPs, APAs, financial transactions, intangibles, valuations and business model optimisation. The firm has strengthened its practitioners through industry schools, business simulations and community of practice activities. The firm has a connection with commerce, country and industry chambers. It also participates in several events, including GST, BEPS, transfer pricing amendments and industry-specific sessions.
In the past year, Pramod Joshi assisted a client with a unilateral APA project. The APA process involved multiple rounds of discussions with the APA authorities on transfer pricing issues. It also included cross-border collaboration with Deloitte USA. Tehmina Sharma also advised an outbound multinational conglomerate on implementing BEPS action plan 13.
In September 2017, the tax division of BMR Group integrated with Deloitte India tax, which build a stronger tax team in India. A group including 20 partners and more than 400 professionals joined Deloitte India across Mumbai, Delhi and Bengaluru. In addition, Deloitte India also hired five senior professionals from other firms.
Dinesh Kanabar is the head of the transfer pricing department. The partners have extensive experience in transfer pricing advisory and litigation practice. The firm advises corporate groups in India on transfer pricing issues, including transfer pricing policy, documentation, APAs and how to restructure businesses regarding transfer pricing policies in India. The firm liaises with the government on the development of policy regarding Safe Harbour Rules, secondary adjustments and other transfer pricing matters.
Sudhir Nayak assisted a large Dubai-based real estate development company with the preparation of Country-by-Country Reports and master files. Ajay Rotti is advising a global component manufacturer on a restructuring of its transfer pricing policy. The firm helped the client move to a new transfer pricing model. The practice is also assisting the client in obtaining an APA regarding the new model.
In 2018, Aditya Hans and Rahul Mitra joined the firm as partners. Rahul Mitra has more than 26 years of experience in dealing with taxation and regulatory matters in India. He specialises in transfer pricing practice, including inbound and outbound planning assignments, advises on profit/cash repatriation planning, supply chain management projects and profit attribution to permanent establishment.
Rohit Jain and Nishant Shah lead the transfer pricing practice at Economic Laws Practice. The firm is made up of professionals with diverse backgrounds, including legal professionals, financial and market analysts, chartered accountants and economists. The team not only provides a comprehensive analysis, but also plans clients’ transfer price. The practice involves transfer pricing study and documentation, intercompany transfer pricing policies for tangible goods, intangibles-related services, transfer pricing planning services, transfer pricing litigation and supply chain advisory. The firm also provides advice on trade and customs, including valuation to be adapted under customs.
In 2017, M P Devnath, Jignesh Ghelani and Vivek Sharma joined the firm as partners. Adarsh Somani and Abhishek Anand joined the firm as associate parners. In 2018, Rahul Charkha joined the firm as an associate partner.
Harsh Shah is the head of the transfer pricing practice at G M Kapadia & Co. He helps clients with international taxation, transfer pricing, non-resident taxation and exchange control laws. The firm provides services involving transfer pricing studies, cross-border transactions, tax representation and tax litigation.
“We work with them on all matters. Very practical approach. Good technical skills. Easily approachable and give us adequate senior partner time.”
Arun Chhabra is the head of the transfer pricing practice at Grant Thornton. The team is led by four partners and four directors. The team has around 75 transfer pricing professionals. The practice includes APA, Country-by-Country Reporting, planning, policy making, implementation, documentation and compliance, as well as defending before the revenue appellate authorities.
Arun Chhabra, Gaurav Jain and Priva Bhutani are advising a client on an APA project. The team helps the client regarding obtaining APA with the Central Board of Direct Taxation. In addition, the team also assisted a client with a Country-by-Country Report. Grant Thornton helped the client in line with master file and Country-by-Country Report requirements.
In 2018, Amit Bhalla joined the firm as an associate director.
The transfer pricing team is comprised of three tax professionals. These are Sanjay Sanghvi, Suraj Kumar Shetty and Raghav Bajaj. The team advises multinational groups on transfer pricing issues and assists with strategy and representation before tax authorities. The practice reviews transfer pricing study reports and documentation requirements. The team provides representation before income tax authorities, including drafting legal documents and submissions. In addition, the firm also offers representation before the Dispute Resolution Panel and Income Tax Appellate Tribunal and assistance in representation before high courts and the supreme court of India. The team advises on the suitability of APAs for cross-border transactions. The practice assists at various stages of APAs, involving pre-filing consultation, negotiations with the Central Board of Direct Taxation and competent authorities for bilateral APAs.
Sanjay Sanghvi and Raghav Kumar Bajaj advised a client on appellate strategy regarding a transfer pricing benchmarking study report and represented it before the Income Tax Appellate Tribunal in a transfer pricing dispute.
In 2018, Indruj Rai, who worked at DSK Legal, joined the firm as a principal associate.
The transfer pricing team is made up of about 350 professionals in India. These professionals come from various backgrounds, including chartered accountants, economists and financial analysts and ex-regulators. These teams are spread across 10 locations in India and are led by 13 partners and 19 advisors, executive directors and directors. The teams provide advice in terms of the knowledge of economic principle and the arm’s length standard. The practice involves integrated advisory, compliance and litigation support services, APAs and three-tiered BEPS documentation.
The firm is assisting CG India with compliance requirement under BEPS action plan 13. In addition, the firm also advised a client on negotiating and concluding an APA on management charges.
The transfer pricing team has one fee earner, who deals with transfer pricing issues in relation to disputes and compliance. The practice advises on transfer pricing proposed by the big four and other legal or tax firms. The practice is used by other firms such as KPMG.
In the past year, the firm helped a client in a matter concerning Indian transfer pricing and APA advice. The innovation was that the firm applied the safe harbor rules to the transfer pricing arrangement. In addition, the team also advised the client on the APA regime, which offers an opportunity for taxpayers to determine the arm’s length price.
Amit Agarwal is the head of the transfer pricing practice at Nangia & Co. The team includes chartered accountants, MBAs, CFAs, economists and legal experts. The firm offers practices including transfer pricing documentation, transfer pricing planning, intra group service documentation, business model optimisation, audit defence and litigation support, APA and MAP. The team also provides services to a wide range of industries, involving oil and gas, e-commerce, hospitality, automotive, technology, media and communications, industrials and manufacturing.
In the past year, the firm provided transfer pricing advisory regarding cost allocation of intra-group services. The team advised a client on justifying the appropriateness and legitimacy of the subject transaction by undertaking a twin approach for benchmarking the issue of payment for intra-group services.
In 2017, Prateek Agarwal and Nitin Narang Tarini joined the firm as executive directors. Nijhara and Anupam Jain joined the firm as associate directors.
Vandana Shah and Gaurav Shah lead the transfer pricing practice at Shah V G & Co. They are supported by two more fee earners. Vandana Shah has extensive experience in cross-border taxation, transfer pricing, the Foreign Exchange Management Act and allied matters. Gaurav Shah has more than 13 years of transfer pricing experience. He previously worked as a director at PwC and BDO India. The firm provides services in technology, shipping and logistics, renewable energy, pharma and manufacturing.
Gaurav Shah advised an Indian company on intra-group cross charges and brand royalties. In the past year, Vandana Shah helped a client to formulate a transfer pricing policy that related to the IP of the group. It also took account of the BEPS guidance and transfer pricing regulations in both India and the US.
In 2017, Gaurav Shah joined the firm as a director.
“Very professional work and timely delivery. They guide us not just on topics which we have engaged them for but also on side aspects that we should take care about related to tax.”
Maulik Doshi is the head of the transfer pricing department at SKP Group. He advises clients on planning, litigation, APAs and contemporaneous documentation studies. The team provides services involving the formulation and implementation of global policy, assistance with respect to special transactions, valuation, benchmarking support, documentation, certification, authority negotiations, APAs and litigation support. In addition, the firm also handles Asia Pacific and global transfer pricing assignments.
Maulik Doshi assisted a client with a transfer pricing issue. In the case, SKP Group studied the entire business model of the group, supply chain structure, flow of transactions and inter-company dependencies. The firm also advised the client on the appropriateness of their existing transfer pricing methodology and recommendations.
“Strengths are that they are competent, professional, committed and show ownership of the work. I can't think of any of their weaknesses that have caused us trouble.”
Himanshu Sinha is the head of the transfer pricing department at Trilegal. The team is also supported by Vrinda Tulshan and Bhuwan Dhoopar. The firm advises on appropriate transfer pricing arrangements that are compliant with Indian tax laws and tax efficiency. The firm provides advice on the impact of IP migration and business restructuring on the extant transfer pricing arrangements of entities. In addition, Trilegal also advises on transfer pricing disputes in litigation at various levels of appeal, especially in the tax tribunal and the high courts. The team prepares transfer pricing documentation based on functional and economic analysis. The practice includes supply chain restructuring, review of agreements from a transfer pricing perspective and structuring costs sharing arrangements for intercompany transactions.
The firm represented a client before the income tax appellate in a transfer pricing dispute including a number of transfer pricing issues of benchmarking of transactions, which involved a dispute on the choice of comparables.
“Trilegal is excellent in transfer pricing litigation work. The partner is personally involved in the work, is an expert in strategically arguing the case before various tax courts. One weakness of the practice is that it is yet to have multi-location footprints, and needs a higher number of prominent tax partners.”
Vispi Patel is the head of the transfer pricing practice at Vispi T Patel & Associates. He has more than 30 years of tax experience involving transfer pricing practice. The firm provides practices, including inbound-outbound strategy, structuring of the economic substance, compliance and documentation services, APAs and litigation support, diagnostic review of transfer pricing methodology and transfer pricing strategy.
In the past year, the firm assisted a client with planning their affairs in line with Indian transfer pricing regulations. They also assisted the client in aligning the international transactions at arm’s length pricing. In addition, the team advised the client on the applicability of the master file and Country-by-Country Report.