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Languages:
English
Hindi
Biography
Sudheer Polana advises multinational enterprises operating in India on transfer pricing, international taxation, and business taxation, with a particular focus on tax controversy management. His transfer pricing litigation and advisory practice involves identifying exposure across transfer pricing and base erosion and profit shifting (BEPS) positions and advising clients on effective risk management and mitigation strategies.
On the compliance and advisory side, Sudheer has developed and implemented transfer pricing policies and intercompany agreements for multinational groups, conducted benchmarking analyses, and prepared and reviewed Local Files, Master Files, and Country-by-Country Reports. His international tax experience includes permanent establishment and place of effective management risk assessments, withholding tax implications on cross-border payments, and BEPS impact assessments for clients adapting to evolving documentation and reporting requirements.
Sudheer is a Chartered Accountant and joined Steadfast Business Consulting LLP's transfer pricing practice in 2024.
Year joined firm: 2024
On the compliance and advisory side, Sudheer has developed and implemented transfer pricing policies and intercompany agreements for multinational groups, conducted benchmarking analyses, and prepared and reviewed Local Files, Master Files, and Country-by-Country Reports. His international tax experience includes permanent establishment and place of effective management risk assessments, withholding tax implications on cross-border payments, and BEPS impact assessments for clients adapting to evolving documentation and reporting requirements.
Sudheer is a Chartered Accountant and joined Steadfast Business Consulting LLP's transfer pricing practice in 2024.
Year joined firm: 2024
Recent Matter / Case Highlights
- Acted on the successful defence of the Residual Profit Split Method against a show cause notice proposing the Transactional Net Margin Method (TNMM) for an Indian telecom platform developer reporting exceptional margins while claiming Section 10AA benefits. Matter value: approximately USD 9 million.
- Acted on the transfer pricing defence of a cross-border biosimilar intangible acquisition under the hard-to-value intangibles framework involving India, Switzerland, and the United States. Disputed value: approximately INR 798 million.
- Acted on a Dispute Resolution Panel defence of a limited-risk software development entity against re-characterisation as a high-end R&D provider across India and China. Matter value: approximately USD 23 million.
- Advised on the restructuring of a contract R&D arrangement and revenue recognition framework, aligning the transfer pricing position with Ind AS 115 and repositioning the entity as a cost-plus contract R&D service provider before the exposure crystallised into a dispute.
- Acted on credit risk-based benchmarking of a USD 25 million corporate guarantee using loss-given-default methodology for India-Korea cross-border financing.
Key Practice Areas
- Transfer pricing
- Transfer pricing policy design
- Transfer pricing risk management
- International tax advisory
- International tax planning
- Tax consulting
- Tax advisory
- Corporate tax
- Tax controversy management
- Dispute resolution
- Litigation
- Pre-litigation advisory
- Audit support
- Audit defence
- Economic modelling
Sector Expertise
- Industrials
- Pharmaceutical and life sciences
- Technology and telecommunications
Education / Alumni
- Chartered Accountant, Institute of Chartered Accountants of India (ICAI)
Bar Admissions
- Institute of Chartered Accountants of India (ICAI),
Address:
Tel:+91 98 4876 2777
Email:Contact this practitioner
Website:https://steadfastconsultants.in/sbc-team/ca-sudheer-polana/
Suite 5, Level 3, Reliance Cyber Ville, Vittal Rao Nagar, Madhapur, Hitech City, Hyderabad, Telangana 500081
India
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