Janvi Chandnani (Chartered Accountant)

· Led the analysis and preparation of Safe Harbour Test workings under Pillar Two – OECD and determined preliminary tax provisioning for MNEs. Additionally, managed registration and notification requirements for jurisdictions like France, Hungary, and UK, and addressed complex queries related to deferred tax treatment in branch accounting and qualifying CbCR requirements for various clients .

· Undertook compliance under SEBI (LODR) Regulations by preparing cover letters, memorandums, and annexures for the review of Related Party Transactions (RPTs) under Section 188 of the Companies Act, 2013 for listed entities.

· Assisted in the client specific advisories for global coordinated documentation (‘GCD’), business modelling, value-based model, group transfer pricing policy framework, measures to strengthen transfer pricing documentation etc. for various clients.

· Undertaking transfer pricing compliances and end to end transfer pricing assessments before various level of appellate authorities for various clients.

Authored an article for Taxsutra analyzing SEBI’s report on royalty payouts by listed companies, supported by in-depth research on OECD guidelines, judicial precedents, and the evolving litigation landscape surrounding royalty arrangements.

· Actively contributed to business developmentby preparation of tailored pitch presentations and briefing notes and participating in client meetings alongside Partners.

Coordinated with risk and compliance teams, and ensured timely billing and adherence to firm-wide risk management protocols.

• Spearheaded comprehensive transfer pricing audits and analyses for multinational enterprises (MNEs) across diverse industries, including listed entities, ensuring timely issuance of Form 3CEB in compliance with Indian regulations.
• Drafted detailed transfer pricing planning memorandums (Local Files), including functional, asset, and risk (FAR) analyses and benchmarking studies for proposed international transactions.
• Supported MNEs in the preparation, maintenance, and filing of Master Files in accordance with Indian transfer pricing documentation requirements.
• Managed end-to-end transfer pricing assessment proceedings, including drafting submissions and representing clients before various appellate authorities.
• Collaborated with legal counsel to develop litigation strategies and briefing notes for defending global transfer pricing positions before tax tribunals and appellate forums.
• Prepared OECD-aligned need-benefit documentation (NBD) for intra-group services, substantiating the arm’s length nature of intercompany charges.
• Assisted in the end-to-end process of Advance Pricing Agreements (APAs), including drafting applications, responding to regulatory questionnaires, preparing for site visits, and supporting negotiation phases for both unilateral and bilateral APAs.
• Contributed to high-impact advisory projects such as tax due diligence for mergers, analysis of deemed international transactions and business restructuring implications for change in billing models, and Uncertain Tax Position (UTP) assessments for financial provisioning.
• Developed and delivered technical presentations on recent tax amendments, judicial precedents, and APA strategies to internal teams and clients.
• Oversaw client onboarding and engagement formalities, coordinated with risk and compliance teams, and ensured timely billing and adherence to firm-wide risk management protocols.

Indirect Taxation:

• Managed monthly GST returns, reconciliations, vouching, and verification for private and listed companies.
• Handled annual audits and filings for various listed entities and private firms.

Corporate Tax:

• Managed end-to-end assessment proceedings, including client handling, authorized representation, and faceless assessments for listed and private companies.
• Drafted submissions and appeals, conducted tax computations, handled reassessment cases, analyzed tax amendments, and researched key Supreme Court and High Court judgments for strategic insights.

Audit and Assurance

• Conducted site visits, vouching, verification, and financial statement preparation for mid-sized manufacturing firms and trusts.
• Led overall audit execution, ensuring adherence to work plans and allocations.