Planning:
Controversy management:
Risk review of inter-company pricing policies to proactively mitigate risks
Manage local country transfer pricing reviews and audits including strategizing responses to tax authorities
Support multi-jurisdictional transfer pricing audit resolution by way of Mutual Agreement Procedure (MAP) by engaging with Competent Authorities (CA), where required
Proactive engagement with tax authorities to minimize transfer pricing controversy by using the Advance Pricing Agreements (APA) mechanism, where appropriate
Conduct due diligence reviews of intercompany transactions and policies, prior to an acquisition.
Operational Transfer Pricing:
Review inter-company results in context of policies including year-end positions
Assist with drafting inter-company agreements
Integrate inter-company accounting and financial systems
Inter-company invoicing
Update pricing policies and review year-end positions, update inter-company agreements, integrate inter-company accounting systems and invoicing following merger/acquisition.
Compliance:
Avinash S. Tukrel is a Principal and leads our Transfer Pricing Practice, based in Toronto, Canada.
As the practice leader, Avinash works with his clients in navigating complex tax and transfer pricing problems with a pragmatic approach collaborating with international member firms in the Moore Global Network.
He has over 15 years of international transfer pricing experience gathered in Canada, the United Kingdom (UK), Malaysia, Australia and India.
Avinash has led numerous transfer pricing planning, compliance, operational and controversy management engagements for his clients in the pharmaceutical and life sciences, technology, consumer and industrial products as well as diversified services sectors.
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