Transfer Pricing Practical Challenges and Latest Developments

September 15 2012, WIRC Seminar on International Tax & Transfer PricingMumbai

Grant Thornton India LLPKarishma R. PhatarphekarPartner and Practice LeaderTransfer Pricing Services

1PROCPL AgendaTP Developments-Budget Amendments

-Specified Domestic Transactions

-Advance Pricing AgreementPractical Challenges in Transfer Pricing-Documentation Challenges

-Practical issues in 3CEB certification

-Litigation Challenges

-Key takeaways

2PROCPLDocumentation ChallengesLitigation ChallengesPractical issues in 3CEB verification Practical issues in 3CEB verificationKey Takeaways3PROCPLDocumentation ChallengesDocumentation ApproachGatherbackgroundinformationAnalyze data and performfunctionalanalysisPreparefunctionalanalysisIntegrateintoTransferPricingstudyTested party &characterizationIdentify industry drivers&characteristicsPreparecomparabilitytable &benchmarkingPrepareIndustry report /analysisIdentify risksand assetsemployed4PROCPLDocumentation ChallengesAvailability of financial information of comparablesAvailability of External Comparables which are functionally similarTransaction-wise analysis vs. aggregation approachProduct-wise analysis vs. Basket of products approachDetermination/Availability of CUP dataAvailability of documentation to substantiate benefit test (Management fees/ Intra-group services)Adoption and identification of appropriate allocation keys for segmental spilt accounts. Break-up of financial accounts to present key segments

5PROCPLDocumentation ChallengesDetermining the type of adjustments to be made to comparable data

Appropriate justification / documentation for adjustments carried out to comparable data.

Availability of Independent Comparables. Companies having no related party transactions

Selection of most appropriate method

Selection of Tested Party

Selection of PLI

6PROCPLDocumentation ChallengesLitigation ChallengesPractical issues in 3CEB verification Practical issues in 3CEB verificationKey Takeaways7PROCPLPractical Issues in 3CEB verification Form 3CEB-Accountants Report

Section 92E requires every person entering into an international transaction to obtain an accountant's reportTo be submitted on or before the due date for filing tax return

Form 3CEB prescribedDeclaration by the accountant about examination of accountsOpinion on information and documents prescribed by Rule 10D and maintained by the assesseAnnexure to Form 3CEB are true and correct

Guidance Notes issued by the Institute of Chartered Accountants of India

An important document for the Assessing OfficerContains summary of international transactions;Contains details of taxpayer;Contains method employed to determine ALP

The information contained in 3CEB helps the Assessing Officer with a overview of the international transactions8PROCPLPractical issues in 3CEB verificationReference ChecksS. No.Particulars1 Reconciliation with related party - AS 182 Reconciliation with Forex Transaction with respect to Notes to A/c3 Sample Testing - Trial balance / Ledger A/c4 Sample Invoice check/ debit notes5 PAN card copy available in file6 Form 27 - If applicable7 Signed Audited Financials8 Segmental Financials verified with audited accounts9 Copies of Agreement10 Budgets/ Forecast11 Management Representation Letter & Appendices thereto12 Tax Assessment inquiry9PROCPLPractical issues in 3CEB verificationIdentification of international transactions to be reported in the Form 3CEB

Check for application of method with relevance to the international transactions.

Circular by CBDT pertaining to "other method".

Check for international transactions falling under specific clauses of Form 3CEB.

Identify transactions with deemed associated enterprise.

Transaction not having effect on profits, income, losses and assets- should it be reported by way of note or disclosed as an international transactions in the Form 3CEB.

10PROCPLPractical issues in 3CEB verificationRelevant supporting/invoices for transactions under disclosures.

Disclosure pertaining to any event underlying to the international transaction which could substantially determine the characteristic of the transaction

Identify the impact of change in definition of international transactions:how to report business restructuring reorganizationhow to value and determine ALP of intangible assets like customer list, human capital and any other kind of intangibles

11PROCPLDocumentation ChallengesLitigation ChallengesPractical issues in 3CEB verification Litigation ChallengesKey Takeaways12Trend of Transfer Pricing Assessment in IndiaTotal adjustment of USD18350 million. in seven rounds of audit completed

*High adjustment on account of transfer pricing issues like marketing intangibles, corporate guarantee, share transfer 2003-04PROCPLLitigation ChallengesIn general, approach seems moving up the value chain and ruling on sophisticated issues but for IT/ITES sector moving to standard approach.National consulting cherry picking fewLast minute Show causenoticesFollowing beneficialPrecedents onlyIndustry wise scrutinyVoluminous data &DocumentationrequestedChallenge of Method/PLI/OP calculationGeneral ApproachDatabasesGlobal (BVD) Indian (Prowess, Capitaline)Use of Information gathered through Notice u/s 133(6)Litigation Approaches14PROCPLLitigation ChallengesSingle year v/s multiple year data

Usage of secret comparables using power u/s 133(6)

CUP vs. TNMM.

Internal TNMM vs. External TNMM.

Diversified view on Marketing Intangibles/Cost Plus vs Global Profit Spilt.

Standard department sets for various industries (IT/ITES, Diamond, Contract R&D, Clinical Trials etc).

Genuine Cost Allocation probed with suspicion.

15PROCPLLitigation ChallengesUnacceptability in regulatory approvals like FEMA, REBI, Banks etc.

Benefit of +/- 5% range under Section 92 C(2)

Reluctance to use foreign database/comparables

General adjustments like capacity utilization, risk and working capital adjustment challenged by tax authorities.

Notional Interest

Treatment of Investment in shares as loan.

16PROCPLDocumentation ChallengesLitigation ChallengesPractical issues in 3CEB verification Documentation and CertificationKey Takeaways17FAR AnalysisImportant to characterize value added and non valued added activities for tested party;Also important for PE attribution analysis and appropriate economic analysisComparability AnalysisAccept-reject needs to be extremely detailed and not casual;Companies with RPT to be excluded;Functional comparability of comparables importantAdjustmentsImportant to quantify and document risk, working capital, idle capacity adjustment upfrontSelection ofPLI and MAMImportant to go through the process of MAM selection in detailFinancial analysis of tested party and comparables consistency and in-depth analysisKey Takeaways183 Global: While selection of comparables for application of TNMM, functional differences needs to be taken into account. : CUP method would be applicable if the rates provided by the NASSCOM report are specific to voice-based ITeS segment and is in line with the man-hour rate prevalent in the industry. : OECD Guidelines state that "in no event can unadjusted industry average returns themselves establish arm's length conditions". However this ruling goes against the OECD Guidelines and even unadjusted industry averages can be used to establish arm's length conditions.2. Toshiba: Mere arbitrary selection of the comparables doesn't provide the AO an opportunity for placing a tax adjustment.Justified and reasonable basis has to be analyzed while selecting comparables.Show cause notice for determination of the arms length price must be issued depending on the basis of material, information or document in the possession of the assessing officer (Mentor Graphics (Noida) Pvt. Ltd Vs. DCIT) (Delhi Tribunal).Selection ofTested PartyNexus with FAR;Critical for implementing global TP policy.DocumentationMust and Mandatory not only TP study but also supporting agreements / documents should be in sync with defenseBenefit test for services essential to be qualifiedEvaluate that documentation does not have negative repercussions from other regulatory and tax perspectiveFinancialTransactions Just because assessee is shareholder, cannot assume nature of transaction to be quasi-equityKey Takeaways (Contd.)193 Global: While selection of comparables for application of TNMM, functional differences needs to be taken into account. : CUP method would be applicable if the rates provided by the NASSCOM report are specific to voice-based ITeS segment and is in line with the man-hour rate prevalent in the industry. : OECD Guidelines state that "in no event can unadjusted industry average returns themselves establish arm's length conditions". However this ruling goes against the OECD Guidelines and even unadjusted industry averages can be used to establish arm's length conditions.2. Toshiba: Mere arbitrary selection of the comparables doesn't provide the AO an opportunity for placing a tax adjustment.Justified and reasonable basis has to be analyzed while selecting comparables.Show cause notice for determination of the arms length price must be issued depending on the basis of material, information or document in the possession of the assessing officer (Mentor Graphics (Noida) Pvt. Ltd Vs. DCIT) (Delhi Tribunal).PROCPLRevenue will never understand business as well as you do AND FOR THE PURPOSES OF TPIf YOU fail to explain your business and pricing in a lucid manner you will encounter ongoing expensive difficulties

Conclusion20PROCPLTransfer Pricing Developments

21Specified Domestic TransactionsBudget AmendmentsIntroduction of APAKey lies in implementationRecent Developments22PROCPLBudget AmendmentsAdvance Pricing AgreementSpecified Domestic TransactionsTP Developments23Specified Domestic Transactions w.e.f. 1 April 2013Advance Pricing Agreement (APA) w.e.f. 1 July 2012Revenue Conferred right to appeal against Dispute Resolution Panel (DRP)

Arm's Length RangePenalty Inserted for non-reportingScope of International Transactions Widened w.e.f. 1 April 2002Powers of Transfer Pricing Officer (TPO) Enhanced w.e.f. 1 June 2002DRP's Powers Clarifiedw.e.f. 1 April 2009Arm's Length Rangew.e.f. 1 April 2002Prospective Amendments Retrospective AmendmentsKey Amendments Budget 2012 Update24PROCPL2 amendments made to make it abundantly clear that the intent was always for the arm's length range to work as a tolerance band and not a standard deduction Safeguard provision also inserted to ensure Assessments closed before 1 Oct 2009 cannot be reopened on the basis of this amendment5% range tinkered to 3%: CBDT expected to prescribe rates not exceeding 3%However, for FY 2011-12 no range prescribed

Arms Length RangeThe retrospective changes are to contravene numerous Tribunal judgments in favour of taxpayers

The amendments would change the status quo for taxpayers for past years open in appeal and where the transfer prices are outside the 5% tolerance band 25PROCPLTPO empowered to determine arms length price based on non-reporting of transactions during the course of assessment proceedings. Non-referral by AO not required.Re-opening of assessment not to be done on account of such amendment though changes on retrospective basis from 1st June 2002Loan guarantee or extended short term liquidity now coveredNo enhancement of income or reduction of refund with respect to completed assessment proceedings under section 147 or section 154 Powers of Transfer Pricing Officer DRP Powers ClarifiedPower to enhance the variations even without taxpayers objectionsDRP provisions extended to cases of search and seizures.

26International Transactionsincludes building, vehicle, machinery, equipment, commodity etc..Tangible Propertyincludes land rights, customer list, brand, human capital, or location related assetsIntangiblesincludes market research, market development, market management etc..

Serviceslending or guarantee, deferred payment or receivableCapital Financingirrespective of any bearing on profit, income or losses, current or futureBusiness Restructuring27PROCPLPenaltiesDefaultPenalty Concealment of income 100-300% of tax on the adjusted amount Failure to maintain documents 2% of the value of each transaction Failure to furnish documents2% of the value of each transaction Failure to report a transaction in accountants report2% of the value of each transaction Maintaining or furnishing incorrect information or documents2% of the value of each transaction Failure to furnish Accountants Report

INR 100,00028PROCPLIncome Tax Notification No.18/2012"Other method of determination of arm's length price 10AB. For the purposes of clause (f) of sub-section (1) of section 92C, the other method for determination of the arms' length price in relation to an international transaction shall be any method which takes into account the price which has been charged or paid, or would have been charged or paid, for the same or similar uncontrolled transaction, with or between non-associated enterprises, under similar circumstances, considering all the relevant facts."3. In rule 10B of the said rules, in sub rule (1), after clause (e), the following clause shall be inserted, namely:-"(f) Any other method as provided in rule 10AB."

Backdrop:Will allow TPO to adopt bright line test etc.. under "Other method". Pursuant to the decision in the case of Genom Biotech.Also a fall out to the clarified definition of international transaction and intangibles in the recent Finance Act 2012.

Impact:Need to have an uncontrolled transaction to use this method. Transactions that could be covered under "other method": quotations, revenue splits, valuation, reimbursements, cost allocations etc.

Dated: May 23, 2012 : Sixth Method "Other Method"29PROCPLBudget AmendmentsAdvance Pricing AgreementSpecified Domestic TransactionsTP Developments30Specified Domestic TransactionsBackground31Co A Profit makingCo B Loss making / Tax HolidayShifting expenses from Co B to Co A at non arm's length curbedShifting sales from Co A to Co B at non arm's length curbedTax Arbitrage opportunitiesTrigger to Domestic TPSpecified Domestic TransactionsDomestic TP-BackdropVarious income-tax exemptions and deductions provide a leeway for taxpayers to over-invoice or under-charge to the 'eligible undertakings' leading to potential avenues for abuse of these incentives, especially between related or closely connected entitiesAssessing Officers could only rely on their 'opinion' for determining the Fair Market Value for expenditures to related parties or in case of tax holiday units transactions with persons with whom they had a 'close connection'Supreme Court in its decision in the case of CIT Vs. Glaxo SmithKline Asia (P) Ltd [26 Oct 2010] suggested inclusion of certain domestic related party transactions within the ambit of Transfer Pricing Provisions

SDTs included within the ambit of Transfer Pricing regulations with effect from 1 April 2012 - Section 92(2A) & Section 92BA Specified Domestic TransactionsIf one of the related Companies is loss making and the other is profit making and profit is shifted to the loss making concernIf there are different rates for two related units (on account of different status, area based incentives, nature of activity, etc.) and if profit is diverted towards the unit on the lower side of tax arbitrage.Sub Section 2A introduced in sec 92 and new section 92BA has been introduced in the TP regs33Coverage Analysis ? Expenditure and Profit linked Deductions

SDT is triggered if the aggregate of the abovementioned transactions exceeds Rs. 5 crore during a financial yearParticularsNatureTransactions withEarlier methodology40A(2)ExpenditureRelated parties definedExcessive or unreasonable expenditure disallowed80A, 80IA(8)Income or expenditureBetween different business units of same tax payer

Fair Market Value801A(10)Profits Close connectionMore than ordinary profitsincluding SEZsSpecified Domestic TransactionsCertain transactions with domestic related parties / persons have been included in the realm of the transfer pricing regulationsIf a given transaction qualifies as an SDT with effect from 1 April 2012 it has to comply with the transfer pricing regulations on par with international transactionsPrimarily the arm's length standard has to be adopted for SDTs and compliance to be duly documentedPenal consequences are entailed in case of non-complianceif SDTs are not planned proactively the same could result in potential double taxationThere are potential overlaps with other laws such as the Companies Act, 1956The APA provisions as of now do not cover SDT

34Existing Provisions vis-a-vis domestic TP applicabilityValue =< Rs. 5 croresValue > Rs. 5 croresPosition in the IT Act remains same as it is till FY 2011-2012 i.e.disallowance of expense which is excessive or unreasonable having regard to FMV, legitimate needs or benefit derived

re-computation of tax holiday deduction having regard to market value or ordinary profits

no method to measure FMV, needs or benefits, ordinary profits

only reporting in Form 3CD or Form 10CCBDomestic TP provisions applicable i.e.

disallowance of expense which is excessive or unreasonable having regard to 'arms length price'

re-computation of tax holiday deduction having regard to 'arms length price'

prescribed methodology to compute 'arm's length price'

in addition to reporting in Form 3CD or Form 10CCB, additional reporting in Form 3CEB duly certified by a Chartered AccountantIn summary, where aggregate transaction value

does not exceed Rs. 5 crores - no additional compliance burden since no change in position of the IT Act as beforeexceeds Rs. 5 crores - additional TP compliances will trigger

Specified Domestic TransactionsManagerial RemunerationPurchase / Sale of sharesPurchase / Sale of assetsPurchase / sale of servicesShared services / facilitiesCharge of Royalty for use of trade mark / trade name / knowhow Purchase / Sale of productsFinancing (Interest expense)Corporate Guarantee chargesManagement cross chargesMaintenance and administrative chargesESOPs / other benefits to KMP Specified Domestic TransactionsTypes of transactions coveredDo 'capital' transactions require SDT compliance? Free of cost services or benefits to tax holiday units to be valued at arms lengthOverlap of SDT compliance with good corporate governance objectivesCompanies falling under Presumptive taxation whether SDT applicable?Although TP compliance is a 'specific anti-avoidance regulation SAAR' it can be superseded by the proposed GAAR rules, if there is an exceptional case of abusive behavior on the part of the taxpayerPenal consequences are very onerous in case of non-complianceNo corresponding adjustment allowed for other party for adjustments made, if any, by the TPO for transactions falling under SDTClose Connection u/s 80IA(10) not defined: Reference can be drawn from AE definition u/s 92A Indirect Holding - Strict and Legal Interpretation Other pertinent issuesSpecified Domestic Transactions

Then, it was mere reporting of transactions in Form 3CD and Form 10CCB, Now, reporting of justification of a price charged along with arm's length price in Form 3CEB (this form would undergo change to accommodate domestic TP)

Then, generic justification or comparison was still sufficient, Now, scientific justification based on prescribed methods is to be maintained

Then, normal documentary evidences were sufficient, Now, TP documentation supported by robust supportings required

Then, related party transactions used to be scrutinized at the assessment stage by the Assessing Officer, Now, the assessee is duty bound to maintain justification and file mandatory Chartered Accountant's report at the threshold

Then, related party transactions not so closely scrutinized by the AO, Now, there will be aggressive monitoring by the TPO/AOTax position then and now !!Specified Domestic Transactions

Compliance requirement Due date of submissionObtain accountants report in Form 3CEB

Accountants report is a brief summary of international transaction (s) and SDT along with the method used to justify the arm's length nature. This document is to be certified by a Chartered Accountant or a firm of Chartered Accountants30th November

of each Assessment Year for international transactions or SDT undertaken during the relevant financial year (April March)

TP documentation (TP Study)

TP study is a detailed documentation relating to international transaction (s) or SDT which is used to justify their arm's length nature. This documentation is to be annually maintained if the aggregate value of the international transaction(s) entered by the assessee exceeds Rs. 1 crore or the aggregate value of SDT exceeds Rs. 5 croresAssessee is required to maintain contemporaneous documentation and need to submit documentation on request by income tax department

Transfer Pricing Compliances triggered for SDTSpecified Domestic Transactions39Entity relatedPrice relatedMethodology related Transaction relatedSpecified Domestic TransactionsDocumentation requirement under section 92D read with Rule 10DPROCPLBudget AmendmentsAdvance Pricing AgreementSpecified Domestic TransactionsTP Developments41APA = Advance Pricing Agreement

Any company having international transactions can opt for APA. Currently, no threshold limit prescribedAPAs to be entered by the CBDT with the approval of Central Govt.No adjustments or penalties if taxpayer applies the agreed transfer pricing methodology in accordance with the APAProvides prospective certainty for new business, expansion into new country(ies), high risk transfer pricing issues, current audit issuesFacilitate voluntary compliance with the countrys transfer pricing rules,Minimizes levels of disputation and gain certainty in respect of tax outcomes from the covered international related party transactionsEliminates the risk of double taxation (bilateral APA)

AdvanceSets transfer pricing (TP) in advancePricingEstablishes arm's length transfer pricing policy for a specified period of timeAgreementBetween the taxpayer and one / more national tax authority agreeAPA42Insertion of Rule 10F to 10T and Rule 44GAApplicability: Applicable to all persons undertaking international transactions or contemplating to undertake international transactionsTypes of APA: Unilateral, bilateral and multilateralAPAUnilateral APA'sBilateral APA'sMultilateral APA'sSolely between a taxpayer and a tax authority

Single mutual agreement between the CA of two tax administrationsMore than one bilateral mutual agreementAPA RulesPre-filing consultations : A mandatory requirement in the process and not an option provided to the tax payer. Anonymous pre-filing consultation allowable. Key features are :-- Pre-filing consultation is not binding on the Board or the Taxpayer determine the scope of the agreementidentify transfer pricing issuesdetermine the suitability of international transaction for the agreementdiscuss broad terms of the agreementCancellation can be done by CBDT for:failure of the applicant to comply with termsfailure to file annual compliance report;material error in annual compliance report; andwhen the assessee does not agree for revision of APAOther Important issues:roll back of the APA not enabledwithdrawal of APA application permitted at any time before the finalisation

APA RulesTiming of application : In case of remaining transactions (i.e. new or proposed) any time before undertaking the transactions. In case of continuing/existing transactions since the application is to be filed before the first day of the relevant previous year, the first year for which a tax payer may be able to apply for an APA would be FY 2013-14;Forms prescribed:

Fees payable:

ParticularsForm No.Application for a pre-filing meeting3CECApplication for an APA3CEDApplication for withdrawal of APA request3CEEAnnual Compliance Report on APA3CEFAmount of international transaction entered into or proposed to be undertaken in respect of which APA is proposedForm No.Transaction upto Rs. 100 crRs 10 lakhsTransaction between Rs 100 cr to Rs 200 crRs 15 lakhsTransaction exceeding Rs 200 crRs 20 lakhsAPA RulesPROCPLAPA ProcessPre-analysisFeasibility StudyPre-filing conferenceFees

ApplicationApplicationPRELIMINARY SCREENINGNegotiationExecutionPost complianceImplementationMonitoringRollbacks not allowedRenewalsDeficiency letter within 1 month46Board Approval

Competent Authority

IndiaOutside IndiaAPA Team (APA director and APA officers)TaxpayerCompetentAuthorityDG International TaxationBilateral / MultilateralUnilateralDiscussionAssociated Enterprise(AE)Tax authorities including experts from economics, statistics, law etc.APA Negotiation ProcessPROCPLAPA Pros and Cons AdvantagesProvides certainty for the future-transfer pricing method-protection against adjustmentsAvoids penaltiesAvoids double taxationPlan future TP strategiesReduces time-cost and effortResolve audit issues for 5 yearsMandatory Pre-filing consultation without any feesPre-filing could be anonymousConsistency in financial reportingDownward adjustments possibleNo parallel TP audits

DisadvantagesUnilateral APAs No certainty on reduction of double taxationBilateral APAs not achievable where:no basis in domestic law to enter into APAscountries do not have DTAs with each otherNo RollbacksTimeframe for concluding the APA?Confidentiality of tax payer informationToo much information at pre-filing stageAnnual compliance auditMere filing does not prevent operation of determination of arm's length price

48Our groundworkDavid Bowen our Strategic Global APA advisor - shared his views on the Indian APA Rules vis--vis global best practices with the APA close group committee;Several meetings with industry personnel and tax authorities in various cities of India were conducted throughout the first week of the rules being announced;First ones to conduct a Webcast on the APA Rules in India;GT India held the first public discussion with tax authorities: We were part of the panel discussion along with the DGIT and the APA director, in the International Tax review conference in Delhi on September 5, 2012Outlook of tax payerOutlook of tax authoritiesOutlook of tax payers and tax authoritiesRollbacks

Rollbacks not enabledPrecedence value for pending litigations / MAPsTime Frame

No time frame to conclude APAPFC to give guidance on timeframeFirewall provisionsNo firewalls provisionsAssured information to be kept confidentialCompliance AuditTo be like regular auditsWill not be rigorous, infact rules specify thatConcernsTaxpayerTax AuthoritiesIndian Government is keen to implement the APA in a positive manner to create tax friendly environmentConsidering the positive mindset of the Indian Government and the need for them to create a tax friendly environment

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