Corporate Tax, Transfer Pricing & International Tax

Direct tax for a company has three layers that run on different clocks: the annual position — the regime choice, the return, and the tax paid through the year; the transactional layer — transfer pricing under ss.161–171, Income-tax Act 2025 (earlier ss.92–92D, Income-tax Act 1961) for every related-party and cross-border transaction; and the defensive layer — assessments, notices, and appeals that can open years after the return.

Each layer depends on documentation made at the time: the transfer pricing study under Rule 10D, the DTAA claim with its residency certificate, and the return with its schedules. Documents made later are documents made in court.

The department's assessment examines the return against the contemporaneous record — the board approvals, the transfer pricing documentation, the agreements. A company that plans the position during the year files a return that is easy to defend; one that discovers its position at filing time files a return that invites scrutiny.

Our engagement is built that way too: the planning memo comes first, the documentation is made as the transactions happen, and the return simply records what was already decided.