After all analyzation and recommendation of BEPS and worldwide in depth scrutiny by the tax authorities mainly involves intangible transactions. Tax authorities are likely to draw inference and support from OECD and BEPS guidelines to determine return from intangibles. This helps us to guide how to analyze Intellectual Property Rights, brands etc. and how they are positioned whether all group members are contributing towards development, enhancement, maintenance, protection and exploitation of intangibles which helps to determine-

1. Location of IPR and place of conceptualization and development of IPR.

2. Legal ownership or beneficiary ownership of intangibles and related payment.

3. Requires providing an overview of MNE’s global chain.

4. Identify whether the revenue and profit generated from all jurisdictions are proportionate with the substance.

5. Detect artificially shifting of the substantial amount of income to advantageous environments having taxation benefits by means of automatic exchange of information between the tax authorities.

6. Recognizing location of the groups where they can enjoy tax incentives.

1. Master file to provide MNEs blueprint.

2. Local file to provide material TP positions of the local entity with its forign affiliates.

3. CBC reporting to provide jurisdiction wise information.

1. We conduct training which will involve knowledge sharing sessions to increase the awareness of three tire documentation requirements, its structure and compliance requirements.

2. Prepare diagnostic review to assist in preparing TO compliance obligation.

3. To analyze the intangible on the basis of BEPS guidance to ensure that the group members are contributing towards enhancement, development, maintenance, protection, and exploitation of intangibles and being remunerated appropriately.

4. To develop processes and procedures for compliance and train the group members to meet documentation deadlines to ensure the alignment between the local and global documentation.