Jurisdictions:
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 work involves identifying exposure across transfer pricing and base erosion and profit shifting positions and advising on how those risks are best managed and mitigated. On the compliance and advisory side, he has developed and implemented transfer pricing policies and inter-company agreements for MNE groups, conducted benchmarking analyses, and prepared and reviewed Local Files, Master Files and Country-by-Country Reports. His broader international tax work covers permanent establishment and place of effective management risk assessments, withholding tax implications on cross-border payments, and BEPS impact assessments for groups adapting to changing documentation and reporting standards. He is a Chartered Accountant and joined the firm's transfer pricing practice in 2024.
Recent Matter / Case Highlights
- Acted on the successful defence of the Residual Profit Split Method against a show cause notice proposing TNMM, for an Indian telecom platform developer reporting exceptional margins while claiming Section 10AA benefits. Approx. USD 9 million.
- Acted on the transfer pricing defence of a cross-border biosimilar intangible acquisition under the hard-to-value intangibles framework across India, Switzerland and the United States. Disputed value approx. 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. Approx. USD 23 million.
- Acted 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.
Sector Expertise
- Industrials
- Pharmaceutical and life sciences
- Technology and Telecommunications
Education / Alumni
- Chartered Accountant, Institute of Chartered Accountants of India (2024)
- Bachelor's degree, Krishna University, Machilipatnam (2022)
Association / Network Memberships
- Institute of Chartered Accountants of India (ICAI)
Address:
Tel:+91 98 4876 2777
Email:Contact this practitioner
Website:https://www.steadfastconsultants.in
Suite 5, Level 3, Reliance Cyber Ville,
Vittal Rao Nagar, Madhapur, Hitech City
Hyderabad, Telangana
500081
India
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