Transfer Pricing

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Our professionals help you build, manage, document, review and support your transfer pricing policies and processes. We work with you to build pragmatic, integrated strategies that address the tax risks of your business and help your business achieve its potential.

We can help you with:

Oversight on the Company’s transfer pricing matters and working with multiple stakeholders to provide support on transfer pricing related issues

Handling transfer pricing analysis and reporting

Provide advice on transfer pricing implications for new business initiatives

Support transfer pricing audits, including responding to tax authorities on matters or queries relating to transfer pricing.

Managing and preparing transfer pricing documentation to support intra-group transactions in compliance with local regulations

Conducting regular internal review of transfer pricing policies in accordance with the latest tax regulation developments

Transfer Pricing Due Diligence

Why is transfer pricing due diligence important during M&A?

Due diligence presents the opportunity for an acquiring company to look at the transfer pricing policies & activities of the target company. Doing so helps identify potential risks; it also forms the basis for analyzing potential future opportunities for policy integration once the acquisition is complete.

Identifying and addressing risks early in the process allows for sufficient planning, and paves the way for a smoother integration. By anticipating future transfer pricing challenges, the acquiring company can put contingencies in the purchasing contract to account for adjustments. On the other hand, lax due diligence has a high price: It can have extensive financial implications down the line, including garnering unwelcome attention from tax authorities.

M&A Due Diligence Checklist for Transfer Pricing

If your company is planning M&A activity and you’re tasked with managing tax due diligence, following checklist might be useful to you…

Evaluate whether formal transfer pricing policies are in place.

Review the target company’s transfer pricing documentation.

Assess the target company’s country-by-country reports.

Review any existing legal agreements for intercompany transactions.

Perform in-depth analysis to determine if transfer pricing risks exist.

Transfer Pricing Designing & Structuring

We can help you with:

Strategy and policy development

Reduce the impact of year-end adjustments

Monitor your transfer pricing footprint

Global or regional assistance to support transitions to new documentation requirements

Controversy risk assessment, remediation or mitigation as a result of documentation requirements

Global transfer pricing controversy and risk management

Mitali Shah

Managing Director & Head (Banking & Restructuring)

Mitali carries the banking relationships for the firm since initiation of her tenure with the organization and actively involves with the lenders to understand their business needs, develop solutions and lead projects from inception to final completion.

She comes with an experience of more than 20 years with specialization in insolvency & resolution practice, real estate and industrial assets valuation, auctions and portfolio valuation, Technical and assurance services. Her role within RBSA involves managing the overall development & operations of the firm with leadership roles across Business Strategy, Business Development, Major Project management and operations of the company.

Mitali heads Restructuring practice of RBSA Advisors. She led the efforts in shaping the Restructuring practice of RBSA which started around 2017. Since then the Restructuring practice has grown to a 50-member team which includes 13 RPs and 37 other professionals. Also, she is specialized in valuation and has been involved in Resolution of Non-performing assets of financial Institutions. She is advising various NBFCs, ARCs and Banks on NPA transactions on Portfolio / Standalone Basis. She is also the practice leader for Asset Valuation for Liquidation, Restructuring, Mergers & Acquisitions, Financial Reporting, Due Diligence, Technical Engagements, Bid Process Management, Auctions, etc.

She is a Civil Engineer and did her Masters of Valuation in plant & machinery. She is Registered Valuer with IBBI under Companies Act for Plant & Machinery and Real Estate. She is also a Member of Royal Institution of Chartered Surveyors (MRICS), UK and Insolvency Professional registered with the Insolvency and Bankruptcy Board of India (IBBI). She is an active speaker at various conferences.

Vinod Nair

Managing Direction & Head (Risk Advisory Services)

Vinod Nair is based out of RBSA’s Mumbai Office and heads the Risk Advisory Services (RAS)

Vinod is a Chartered Accountant with more than 25 years of experience in delivering Risk Advisory solutions which also includes working in leadership roles with global professional services firms like EY, Grant Thornton, BDO and Baker Tilly.

Vinod has held National Leadership positions in RAS which included handling a team of partners and 100+ professionals pan India across Process, Information Technology and Forensic risk domains. Vinod’s expertise is in providing Corporate Governance Advisory in the areas of Business Process, Risks & Controls; His key domain areas of experience include Internal audit, Implementing Enterprise Risk Management framework, SOX advisory, IFC advisory, and process optimization. Apart from working for several elite clientele in India, Vinod had the opportunity of delivering RAS engagements for Indian/ global MNCs in several countries including the US, Africa and Armenia.

Vinod’s experience in delivering RAS assignments spans across diverse industries like Pharmaceuticals & Healthcare, FMCG, Auto & Auto Components, Financial Services, Mining & Metals, Oil & Gas, and real estate.

Rajeev R. Shah

Managing Director & CEO

Rajeev is the Managing Director & CEO of RBSA Advisors. His role spans across various verticals ranging from managing the overall development and operations of the firm with leadership roles across business strategy, business development and management of various advisory practices of RBSA.

Rajeev specializes in Mergers & Acquisitions, Financial Valuations, Due Diligence, Fund Raising Advisory etc. He has been involved with some of the major Mergers & Acquisition Engagements in India, as well as the Major Disinvestment and Privatization assignments on behalf of Government of India. His clients include leading Banks, Financial Institutions, Private Equity, Government & Regulators, major Indian Companies and MNCs.

He is a Mechanical Engineer, MBA & CFA; he has specialized in Valuation and accredited himself as a Master of Valuation in Real Estate (Gold Medalist) and Master of Valuation in Plant & Machinery (Gold Medalist). He is one of the very few individuals who are Registered as a Valuer by IBBI under Companies Act for all three categories viz. Securities & Financial Assets, Plant & Machinery and Real Estate. He is also an Eminent Member of RICS, UK and Chartered Valuer and Appraiser (CVA) from IVAS, Singapore. He is registered as an Insolvency Professional with IBBI. Rajeev is an active Speaker at various National & International Forums and Conferences.

Ravi Mehta

Managing Director and Head (Transaction Tax)

Ravi Mehta leads the Transaction Tax (M&A-Tax) practice of RBSA Advisors as a Managing Director. Being a Chartered Accountant by qualification, Ravi has previously held senior positions at EY, PwC and Grant Thornton before joining RBSA.

With his addition to RBSA’s Leadership Team, RBSA Advisors has strengthen their value proposition to clients by offering comprehensive Deal Tax Advisory on M&A transactions such as Tax Due-diligence, Tax Structuring, Deal Negotiation Advisory, Transaction Documentation & Post Deal Integration, Building Tax and Regulatory efficiency with robust Corporate/Business Restructuring Solutions (covering Group Restructuring, Financial/Capital Restructuring, Succession Planning, etc.), and supporting their holistic/effective implementation.

Ravi brings more than two decades of experience, having worked on plethora of M&A and Corporate Restructuring transactions across sectors including Technology, Communication, Media, Financial Services, Healthcare, Pharma, Manufacturing, Logistics, Infrastructure, Real Estate, Hospitality, etc., and having supported wide spectrum of clients, including large Business Houses, Business Owners, MNCs and Private Equity.

Chetan Khandhadia

Managing Director & Head (Transaction Services)

Chetan heads the Due Diligence & Transaction Services practice of RBSA Advisors. Prior to joining RBSA in December 2019, Chetan spent 20 years with PricewaterhouseCoopers (PwC) and 4 years with Grant Thornton (GT). Chetan was due diligence partner with PwC for 10 years and headed due diligence practice of GT. He was office managing partner of PwC Ahmedabad for 3 years. He worked with Capital Market magazine and Hinduja Finance Corporation for 3 years as Research Analyst before joining PwC.

Chetan comes with more than 27 years of experience and deep understanding of mergers and acquisitions (M&A), private equity (PE) and IBC transaction process. Chetan’s expertise includes transaction support by performing financial due diligences, buy side and vendor side, inbound and outbound transactions. He brings in business, commercial, valuation and tax aspects related to the transaction. He provides inputs on the transaction closing, business and share purchase agreements. He has worked on several marquee and big transactions and have worked on companies across various sectors.

Chetan is 1992 batch Chartered Accountant from the Institute of Chartered Accountants of India, a ranker in CA Intermediate exam, and is a commerce graduate from R. A. Podar College of Commerce and Economics.

Chetan studies BhagavadGeeta and at Brahma Kumaris World Spiritual University. He did his Masters (MA) in Yoga Shastra and Diploma in yoga education – Teacher’s course in yoga. As a part of community service and spread spiritual and yoga awareness, he conducts yoga sessions regularly and has led yoga camps for the international yoga day celebrations.

Ajay Malik

Managing Director & Head (Investment Banking Advisory)

Ajay leads the Investment Banking Advisory for RBSA Advisors with a principal focus on debt and equity fundraising and M&A Advisory. Based in Mumbai, Ajay has over 25 years of experience in Investment Banking Advisory, Principal Investing, Corporate & Project Lending, and Management Consulting. He has held leadership roles on several for over the last 15 years and built organizational teams from almost scratch to a significant business on a few occasions.

In terms of advisory, Ajay has previously worked with corporate finance advisory divisions of Ernst & Young, KPMG, and Arthur Andersen, covering clients in the Middle East, India & Asia. He also led the financial consulting business for Nomura Research, a Tokyo listed consulting firm, in India covering Asia and Africa region.

In terms of principal investment and lending, he has worked with IFC-World Bank Group, handling origination, execution, and portfolio management of investments across equity, debt, and mezzanine in Europe, Middle East & North African region. He also worked with Standard Chartered Bank, where he was involved in providing working capital and term finance to several large sovereign and infrastructure contracting clients in the Gulf region.

Ajay is a CFA (US), a Designated Credit Professional, an MBA in Finance, and a Bachelor of Electrical Engineering.

Ravishu Shah

Managing Director & Co-Head (Valuation)

Ravishu co-manages the valuation practice of RBSA and brings with him a rich experience of 23 years in the area of Valuation. His valuation experience encompasses Exchange Ratio Recommendation, Purchase Price Allocation, Valuation for Transfer Pricing, Negotiation Support, Entry/Exit of Joint Venture Partners, etc. across various industries. He is a part of the Working Group of ICAI for the formulation of ICAI Valuation Standards and a speaker at various forums including ICAI, WIRC, Chamber of Tax Consultants, etc.

Prior to joining RBSA Advisors, Ravishu was an Executive Director with PwC India in Valuations team. He has worked with PwC India for over 18 years and with ACC Limited (Now part of Holcim Group) for over 4 years.

Ravishu is a Chartered Accountant from Institute of Chartered Accountants of India and Master of Finance from Institute of Chartered Financial Analyst of India and also Registered as a Valuer by IBBI under Companies Act for Securities or Financial Assets (SFA).

He is an Associate Member of the Institute of Chartered Accountants of India and also a member of Association of Certified International Investment Analysts and Institute of Chartered Financial Analysts of India.

Manish D. Kaneria

Managing Director & COO

Manish is COO and is one of the prime movers for RBSA’s growth and actively manages the overall operations. He also co-heads the Valuation practice of RBSA Advisors, with focus on Industrial Valuation.

He comes with an experience of about two decades. He specializes in Industrial Valuation and Technical Due Diligence for Mergers & Acquisitions, Financial Reporting, Lending, Litigation and Restructuring purposes. He has served clients across various industries having distinct focus on Power, Metals, Mining, Manufacturing, Infrastructure and Telecom.

He is from Science Faculty and further specialized in assets valuation by doing Master of Valuation in Real Estate as well as Plant & Machinery. He is Registered as a Valuer by IBBI under Companies Act for Plant & Machinery and Real Estate. He is also a Member of Royal Institution of Chartered Surveyors (MRICS), UK. and Insolvency Professional registered with the Insolvency and Bankruptcy Board of India (IBBI). Manish is an active speaker at various conferences.