Case Studies

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Over the years, SKP has assisted over 1,200 clients from over 45 countries in doing business in India and abroad. Our clients include Fortune 500 companies, multinational corporations, entities listed on global exchanges, private equity/venture capital–owned companies and family-owned businesses. Here are a few examples of our work where we've helped our clients in dealing with the various complexities of doing business in India and abroad.

Defending transfer pricing method used by a global cosmetics company

Engagement: SKP was engaged by a leading global cosmetic company to defend the management fee charge by the foreign parent to the Indian subsidiary before the Indian transfer pricing authorities. We also had to defend the transfer pricing method used by the taxpayer against the method used by the tax authorities at the audit as well as Appellate levels.

Based on the facts of the case, OECD Guidelines, Indian Regulations and Court Rulings, our team defended the transfer pricing method used by the taxpayer. The benefit derived by the Indian subsidiary and passing the “benefit test” was demonstrated to the Indian transfer pricing authorities at various levels.

Value Delivered
There was no adjustment on account of management fees, which in earlier years had been disallowed entirely. The Appellate ordered in favour of the taxpayer, leading to huge tax savings for the client over a span of five years (and counting).