RFP No:RFP-HS4TB-2024-01

RFP Title:Transfer Pricing Study

RFP Issued By:MSH India Health Management Private Ltd.

Issuance Date: July 9, 2024

Registration for Information:

To ensure you receive modifications to the RFP, send an email to Procurement@msh-india.inrequesting that your organization be put on the distribution list.

Submission of Questions regarding the RFP:

Questions regarding the RFP should be submitted in writing to Procurement@msh-india.inno later than July 15, 2024. MSH will send answers to questions to all registered parties.

Closing/Submission Date and Time: July 18, 2024, 5 PMIST

Language of Proposals:The technical and cost proposals must be in English.

Instructions for Submission of Proposals:

In order to be considered, complete technical proposal and cost proposal must be submitted by email to Procurement@msh-india.in by the closing date and time. See Section 5 of the RFP for detailed delivery instructions.

Estimated Period of Performance: July – August 2024 (till August 31^st, 2024)

Award:

A Fixed Price Deliverable-Based Subcontract is anticipated. Issuance of this request for proposals does not constitute an award commitment on the part of MSH nor does it commit MSH to pay for costs incurred in the submission of a proposal.

A. TITLEOF

MSH India Health Management Private Ltd seeks a contractor to provide support in ensuring compliance with transfer pricing guidelines and providing guidance in planning and optimizing transfer pricing policies.

B. BACKGROUND

MSH India Health Management Private Ltd is an advisory organization that provides management, operational, scientific, technical, business, information technology development, project development, facility management, research & training and other support services to improve health, including interventions to increase access to, quality and efficiency of health service organizations and delivery and/or provision of services related to healthcare, across all health areas. The Company is implementing a project in India called ‘Health Systems for TB’ (‘HS4TB’) where key focus areas are streamlining the procurement process, formalizing partnerships with various stakeholders and payment processes.

C. OBJECTIVES

The main tasks and responsibilities under this assignment are to conduct a functional analysis, an economic analysis, and develop a Transfer Pricing Review memorandum. The assignment will include conducting industry research, staying updated on transfer pricing regulations, analyzing organizational data, running comparable sets, and preparing reports.

D. SCOPE OF WORK /SERVICES TO BE PROVIDED

1: Functional analysis

• The aim of the functional analysis is to describe the functions of the Company, particularly focusing on the international transactions entered between the Company and its associated enterprises (hereinafter referred to as ‘AEs’) during the year.
• The functional analysis will involve an assessment of the functions performed, assets utilized, and risks assumed by the Company and its AES.
• In addition, the functional analysis will describe any uncontrolled transactions entered into by the Company and the relevance, or otherwise, of these uncontrolled transactions in the assessment of the Company’s transfer pricing position with its AES.
• Undertake functional analysis discussions with the Company’s personnel in key functional areas. These discussions, and other information, will form the basis of the functional analysis. In addition, document the nature of the relevant industry in which the Company operates with particular emphasis on those factors impacting the Company performance during the period of review.

2: Economic analysis

• This entails documentation of the most appropriate method to be adopted for transfer pricing analysis, including why a particular method is considered most suitable to the facts and circumstances of the taxpayer. We will conduct a review of available independent transactions or operations, which could be considered potentially comparable to the Company’s business.
• Should use internal comparable transactions entered with independent entities (i.e. transactions entered between the Company and independent third party comparable to international related party transaction or specified domestic transactions) to evaluate the performance of the Company, this step will involve a qualitative and quantitative analysis of these transactions together with the performance of adjustments to enable closer comparability with transactions undertaken by the Company.
• If it is not possible to use internal comparable in evaluating the Company’ transfer prices, and alternate methodologies are chosen, then conduct a search of external databases, to identify comparable companies.
• This step will involve quantitative and qualitative screening of these transactions together with the performance of adjustments to enable closer comparability with transactions undertaken by the Company.
• The quantitative screening would involve computation of certain key financial ratios of comparable companies and the Company to eliminate companies, whose financial ratios are significantly different from those of the Company.
• The qualitative screening would involve perusing business descriptions of the remaining companies to select the close comparable companies.
• The final set of comparable entities thus obtained, along with their relevant financial parameters, would be considered for the purposes of determining the pricing methodology for the international transactions between the Company and its AEs.

3: Preparation of Transfer Pricing Review Memorandum

• Based on the above, prepare the Transfer Pricing Review Memorandum in respect of international transaction as provided by the Company.
• Present the draft memorandum to the Company for review and incorporate feedback.

E. EXPECTED DELIVERABLES

Prepare a Transfer Pricing Review Memorandum in respect of international transactions as provided by the Company.

Describe the different transfer pricing methods which could be used for examining the arms-length price of the controlled transactions and suggest the best suitable method.

Provide a detailed transfer pricing analysis report and recommendation of the method and rate for determining the arms-length price.

F. EXPECTED TIMELINE

It is anticipated that this scope of work will be a consultancy contract through August 2024. Dates of delivery for each deliverable will be confirmed with project leadership.

Deliverable	Deadline
DRAFT Transfer Pricing Report	15.08.2024
Final Report	31.08.2024

For detailed information, please check the complete version of the RFP attached below.