Details

Inter-company pricing and business operating models play a crucial role in tax efficiency, profitability, and regulatory compliance for multinational enterprises. Proper structuring ensures that transactions align with Arms Length Principle, support operational goals, and meet global tax standards.

We offer expert guidance on designing and optimizing inter-company pricing arrangements and restructuring models for long-term tax and operational efficiency.

Scope of Advisory

• Inter-company pricing reviews and design

• Supply chain and value chain optimization

• Cross-border business restructuring

• Profit allocation and functional risk analysis

• Support for new business model implementations

Our Services Include

• Cost-sharing and service fee structuring

• Royalty, licensing, and IP pricing models

• Permanent Establishment (PE) risk identification

• Documenting operating model and agreements

• Compliance with BEPS and Indian TP laws

Documents / Inputs Required

• Inter-company agreements and transactional data

• Financial and operational details

• Entity roles and responsibility mapping

Deliverables

• Operating model restructuring report

• Tax-efficient pricing strategy documentation

• Implementation support with compliance alignment