Transfer Pricing

Services

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 MBG Corporate Services - AN INTRODUCTION

Vision and Values

WHAT MAKES MBG DIFFERENT?

our services

CONTENTS Affiliations

OUR SERVICES

Our Team

Our Credentials

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 MBG Corporate
Services

AN INTRODUCTION

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 Your Global Business Experts

Coverage Europe, Middle East & Asia

Headquartered in Singapore
Established in 2002

5K+ | Clients Globally

100+ | Fortune 500 clients served
600+ | Professionals & experts employed
15 | offices in 8 Locations
20+ | Nationalities

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 Vision and Values

We aspire to be recognized as a leading provider of corporate services in

VISION the region, driven by our commitment to excellence and our passion for
helping businesses succeed.

Agility Diversity Reliability

Values
Collaboration Proactiveness Quality
Growth Innovation

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 WHAT MAKES MBG DIFFERENT?

Our senior team has extensive

Industry We leverage our senior Regulatory regulatory experience which
team's long years of
experience across allows us to perform
industries to provide comprehensive analysis of
specialized knowledge applicable laws and regulations,
and expertise and offer proactive compliance
valuable insights and strategies, and ongoing
360 degree monitoring to ensure
recommendations to
advisory and adherence to all regulatory
clients.
integrated requirements.
multidisciplinary
approach

Consulting We bring a diverse

range of perspectives
and solutions to our
clients' business
challenges, drawing on a
wealth of past successes
and a large spectrum of
assignments conducted.

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 END-TO-END SOLUTIONS FOR BUSINESS GROWTH
• Expansion
Strategy
• Diversification
• Policy Revision
• New Products
• New Markets
• Exit Strategy
• New technologies
• Policy Review & systems
• Expansion Strategy
• Maintaining EXTENSION
• Policy Formulation
margins
• Increasing Revenue
• Compliance
• Increasing Customers
• Accounting MATURITY
Management
• Profitability • Effective
• Market Entry Management
• Establishing Business
SHAKEOUT
Structure
• Financial Management
• Effective Risk
Management
GROWTH

LAUNCH

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 our services

RISK ADVISORY MARKET ENTRY TRANSACTION ADVISORY

• Internal audit • Market Research

o Consumer Behavior and Market Segmentation • Preparation of Teaser and Information Memorandum
• Business health check Studies (IM)
• Dealership audit/review o Brand Perception, Tracking, and Positioning • Financial Due-diligence
• SOP development and refinement Studies
• Operational Due-diligence
• ICFR documentation and testing o Customer Satisfaction and Loyalty Studies /
Sentiment Analysis • Tax Due-Diligence
• Entity-level controls policy drafting • Legal Due-Diligence
o Focus Groups and In-depth Interviews
• Business process re-engineering • Transaction Valuation
o Usability Testing and User Experience Research
• Transaction monitoring support • Post Merger Integration Support
o Customer Journey Mapping
• Asset verification services
• Market/Location Feasibility Study
• Scrap validation services
• Market size & Potential
• Forensic advisory services:
• Customer & Competitor Analysis
o Corporate intelligence
• Product Mix Strategy
▪ Integrity due-diligence
• Regulatory Scenario
▪ Third-Party due-diligence
• Evaluation of Entry Strategies
o White-Collar investigation
• Importer / Distributor Search
• Legal Structure Creation

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 our services

CORPORATE & EXPAT TAX TRANSFER PRICING INDIRECT TAX

• Corporate tax services • Pre-benchmarking Advisory • Goods & Services Tax (GST) Services
o Withholding Tax (TDS) Compliances • Business Model Advisory o GST Departmental Audit Support
o Advance Tax Computation • TP Due-Diligence o GST Refunds
o Corporate Tax Return Compliance • Documentation Report o GST Compliance
o Corporate Tax Health Check • Assessments & Litigations o GST Health Check
• International tax services • Master File & CbCR Reporting o GST Advisory
o Permanent Establishment Advisory • Group Transfer Pricing Policy Formation & o GST Assessments & Litigation
Review
o Place of Effective Management Advisory • Custom & DGFT-related services
• Inter-company Agreement- Review & Drafting
o Source-based income Taxability Advisory o Trade remedies under anti-dumping and
• Advance Pricing Agreement (APA) countervailing duties
o Related Compliances & Litigation Services
• TP Health Check o Authorized economic operator program
• Expatriate tax services
o Custom valuation and assistance in SVB
o Tax Computation investigation
o Income Tax Return Filing o Representation on DGFT matters
o Assessments & Litigations o Foreign Trade policy procedures incentives
o Expatriate Tax Health Check o Custom Litigation

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 our services

FINANCIAL REPORTING CORPORATE & OTHER HUMAN CAPITAL

ADVISORY REGULATORY ADVISORY CONSULTING
• GAAP transformation • M&A, JVs and general corporate
• External HR Support
• Accounting advisory support • Fraud recovery and settlements
• Performance Enhancement Training
• Consolidation and closures • Legal assistance, disputes and arbitration
• Payroll management
• Audit support • Employment and labor
• Compensation benchmarking and structuring
• Financial instruments • Capital market & security laws
• Recruitment Service
• IND-AS review • Real estate matters
• Regulatory approvals
• Competition laws
• Bankruptcy and insolvency
• International trade and WTO disputes
• Commercial and EPC contracts
• Secretarial compliances
• Government Schemes/ Incentives advisory

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 Affiliations
GOVERNMENT BODIES BANK EMPANELMENT

PARTNER NETWORK CHAMBERS & TRADE BODIES

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 OUR SERVICES

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 SERVICES PROVIDED BY mbg

Pre Transaction Services Post Transaction Services Other Services

Business Model Planning TP Form i.e. Form 3CEB

Drafting of Group TP policy
Need Benefit Analysis
TP Documentation Report

Ascertaining TP Policy
Master Filing i.e. Form 3CEAA TP Assessments
Documentation under Rule
10D
India to addendum Master File
Intercompany Agreement
Advance Pricing Agreement
Country by Country Reporting (APA)
Documentation Trail (CbCR)

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 Post transaction services

TP Documentation Report
TP Form i.e. Form 3CEB
Every company who has entered into an Every company who has undertaken an
international transaction with its AE international transaction exceeding INR
during a previous year shall obtain a 1 Crore shall keep and maintain such
report in Form 3CEB from an information and documents as listed in
accountant and furnish such report on Rule 10D in respect of such transactions
or before the specified date duly signed as may be prescribed (i.e. TP Study
and verified in the prescribed manner Report or Local File)
by such accountant. TP Study Report comprises overview of
Form 3CEB is to be filed on or before group, Industry Analysis, FAR analysis,
31st October of the assessment year. Economic Analysis, Evaluation of
method, etc.
It is a supporting document which helps
in TP assessments.

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 Post transaction services

India to addendum Master File

(CbCR)
Country by Country Reporting
Master Filing i.e. Form 3CEAA

PART – A : - Every constituent entity It is applicable in case of multiple Form 3CEAC : - It is an intimation of details
who has entered into an international constituent entities résident in India. of parent entity/alternate reporting entity
not resident in India by the constituent
transaction shall furnish the basic It is an intimation given by the entity in the prescribed form . It is to be
details of the international group in the constituent entities about the filed on or before two months from due
prescribed form. designated constituent entity in India date of CbCR.
PART – B : - Every constituent entity in the prescribed form i.e. Form 3CEAB Form 3CEAD : - It is a reporting by a parent
whose - Consolidated revenue of the Form 3CEAB is to be filed on or before entity or the alternate reporting entity
international group exceeds INR 500 31st October of the assessment year.
resident in India in the prescribed form. It
crores ; and Aggregate value of the is to be filed on or before 12 months from
international transaction exceeds INR the end of the accounting period.
50 crores, or aggregate Value of Form 3CEAE : - It is an intimation on behalf
international transaction pertaining to of the International group in case there is
intangible property exceeds INR 10 no agreement for exchange of CbCR by
crores. constituent entity in the prescribed form. It
is be filed on or before 31st January of the
Form 3CEAA is to be filed on or before assessment year.
30th November of the assessment year.

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 Our Team

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 Leadership profile

Mayur Batra is the Founder, President and Executive Chairman of MBG

Corporate Services.
Mayur has over two decades of experience in advising multinationals and
enterprises on a spectrum of matters relating to foreign investment policy, cross-
border transactions, tax controversy, foreign exchange control regulations and
corporate laws and business re-structuring. He has expertise in the area of
international tax policy and contentious cross-border tax treaty issues in overseas
territories. He has been actively involved in obtaining various statutory and
regulatory approvals, licenses, clearances etc., from statutory agencies. With his
vast experience he brings in-depth expertise of converting complex business
transactions into viable profitable propositions.
Mayur has played an instrumental role in expanding the firm’s practice over
diverse service verticals in the UAE region including its empanelment as an ICV-
MAYUR BATRA certifying approved body by ADNOC. Prior to setting up MBG, Mayur has served
Executive Chairman as the Chief Financial Officer at the corporate office of one of the largest Japanese
Trading houses. He has also served as the General Secretary for a term of three
years at the Japanese Chamber of Commerce and Industry in New Delhi.
Mayur has over the years received several accolades and recognitions. He is a
qualified Chartered Accountant & Cost and Works Accountant from India.
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 Leadership profile

N.P. Sahni has undertaken important assignments in India and abroad as Vice
Chairman - Income Tax Settlement Commission, Director General of Income Tax
(Investigation), Chief Commissioner of Income Tax, Joint Secretary (Foreign Tax
Division), Member-Management Committee of Commonwealth Association of
Tax Administrators London (UK), besides holding Tax Policy and Double Taxation
Avoidance Agreement with different countries.

He has also held a senior position in the Revenue Department of Government of

India & Directorate of Enforcement (Foreign Exchange Regulations).

N. P. SAHNI
Chief Advisor & Mentor

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 Leadership Profile

Janardan Singh is COO at MBG Corporate Services and has over 17 years of post-
qualification experience in consulting dealing with matters pertaining to corporate tax,
international tax, transfer pricing, expatriate tax and due diligence.

Janardan has focused on International Tax and Corporate Tax issues related to EPC
contracts/project office operations as his area of specialization. He possesses insight into
various issues faced by multinational enterprises operating in India.

Janardan has worked on issues related to permanent establishment, source-base taxation of

income such as royalty/fee for technical services (FTS), due diligence and he has significant
experience in the area of inbound investments and cross border advisory.

He has done extensive representations at the assessment and appellate level on the issues of
permanent establishment, expatriates taxation and taxation on the basis of source rules for
several corporate entities and individual expatriates.

JANARDAN SINGH Janardan is a qualified Chartered Accountant (CA) of India and holds the degree of Bachelor
Chief Operating Officer of Commerce (B. Com) from University of Delhi, India.

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 Execution Lead

LUV MALHOTRA Chun Chun Goel RASHI PALIWAL ITI GOEL SAURABH SHRIVASTAVA
Associate Partner Associate Partner Director Associate Director
Deputy COO &
Transfer Pricing Indirect Tax Human Capital Consulting Risk & Transaction Advisory
Partner Legal & Secretarial

RUCHIKA JAIN HIMANSHU SURYAN

Assistant Director Assistant Director
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 Relationship Management

SACHIN JAYACHANDRAN JITESH AZAD PRATEEK ARORA HARSHDEEP SINGH

MR. SHUBHAM CHADHA
Partner Director Assistant General Manager Senior Manager
Manager
Business Development Business Development Business Development Business Development
Business Development

RATIKA DHAWAN KARTIK NITNAWARE CHHAYA CHAUDHARY

SIDDHARTH KUMAR VAISHNAVI GEHLOT
Manager Senior Executive Executive
Manager Assistant Manager
Business Development Business Development Business Development
Business Development Business Development
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 Foreign Enterprise team

AKIKO YAMANE LYDIA WUMMEL-TYAGI ISABELLA SUN

Partner Partner General Manager
Foreign Enterprise Team European Enterprise Team Chinese Enterprise Team

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 Our Credentials

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 Our Global Credentials

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 OUR GOVERNMENT CREDENTIALS

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 OUR KEY CREDENTIALS (1/2)

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 OUR KEY CREDENTIALS (2/2)

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 Thank you!
Contact us:
Website: www.mbgcorp.com/in
Email: [email protected]
Contact No: +91-886019008
This presentation has been prepared for the Client and Group personnel only. The information contained in this
document is for general information purposes only. While the Group endeavors to keep the information up to date and
correct, we make no representation or warranties of any kind express or implied, about the completeness or warranties
of any kind, express implies, about the completeness accuracy, reliability, suitability or availability with respect to the
document or the information provided therein, The group reserves copyright of this document and hence, does not
allow anyone to sell, re-publish or re-distribute the document or derivatives thereof.

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