Transfer Pricing

Thorough transfer pricing compliance that safeguards against penalties so you can seamlessly expand your international operations.
Transfer pricing services

Transfer pricing services are critical for businesses with international operations. With tax authorities increasing scrutiny of cross-border transactions, proper documentation and compliance have become essential to avoid disputes and penalties. Whether you’re a multinational corporation operating in India or an Indian company with foreign affiliates, expert guidance is necessary to meet regulatory requirements and establish defensible pricing policies. 

Our dedicated transfer pricing services provide clarity and protection, ensuring you remain compliant with Indian transfer pricing regulations while managing your global tax position effectively. Our professional advisors help you understand complex transfer pricing rules and develop suitable strategies that align with your business structure.

What Is Transfer Pricing?

Transfer pricing refers to the rules and methods for pricing transactions between associated enterprises. In India, transfer pricing provisions were introduced in 2001 through the Income Tax Act, requiring that international transactions between related parties be conducted at arm’s length prices – prices that would be charged in similar transactions between unrelated parties.

Transfer pricing in India is governed by Sections 92 to 92F of the Income Tax Act, 1961, and associated rules. These regulations require extensive documentation, annual reporting, and potential adjustments since transactions have to be maintained at arm’s length. Non-compliance can result in significant penalties, tax adjustments, and protracted disputes with tax authorities.

Who Needs Transfer Pricing Services?

Our transfer pricing services are specifically designed for:

  • Multinational corporations with Indian subsidiaries or operations
  • Indian companies with international transactions with related parties
  • Foreign entities establishing operations in India
  • Global organizations restructuring their international operations
  • Companies facing transfer pricing audits or assessments
  • Businesses looking to implement or review transfer pricing policies
  • Enterprises requiring mandatory transfer pricing documentation
  • Organizations seeking advance pricing agreements
  • Groups subject to Country-by-Country reporting requirements
  • Companies planning international expansion or new cross-border arrangements

Benefits of Transfer Pricing Services

Working with professional services for your transfer pricing needs offers numerous advantages:

  • Expert Guidance: Benefit from specialized knowledge of transfer pricing regulations
  • Risk Reduction: Minimize the risk of transfer pricing adjustments and penalties
  • Documentation Support: Maintain proper records that satisfy regulatory requirements
  • Strategic Planning: Develop tax-efficient transfer pricing policies aligned with business goals
  • Global Consistency: Ensure consistent application of transfer pricing methods across jurisdictions
  • Peace of Mind: Feel confident your cross-border transactions meet arm’s length standards
  • Resource Efficiency: Focus on your core business while experts handle transfer pricing matters

Types of Transfer Pricing Services We Cover

Our specialized expertise spans all critical areas of transfer pricing:

Transfer Pricing Documentation

Comprehensive documentation meeting statutory requirements including background information on the company and its associated enterprises, functional analysis documenting functions performed, risks assumed and assets employed, industry overview, and benchmarking analysis to establish arm’s length nature of international transactions.

Transfer Pricing Study Reports

Detailed analysis and reports establishing the arm’s length nature of international transactions, including selection of most appropriate method, identification of comparable companies, financial analysis, and economic adjustments.

Form 3CEB Certification

Professional preparation and certification of Form 3CEB, the mandatory annual report for international transactions with associated enterprises, ensuring accuracy and compliance with legal requirements.

Master File and Country-by-Country Reporting

Assistance with preparation and filing of Form 3CEA Part A (Master File) applicable to all constituent entities, and Part B (Country-by-Country Reporting) for group entities meeting specified thresholds under the Income Tax Act.

Safe Harbor Applications

Support with applications under Safe Harbor Rules, helping eligible taxpayers choose this option for certain categories of international transactions to reduce compliance burden and provide tax certainty.

Advance Pricing Agreements (APAs)

Guidance throughout the APA process, including feasibility analysis, application preparation, negotiation support, and implementation assistance to obtain certainty on transfer pricing methods and outcomes.

Intercompany Agreements

Drafting and reviewing intercompany agreements to formalize transfer pricing arrangements, ensuring they reflect actual business operations and support the arm’s length nature of transactions.

Transfer Pricing Planning

Strategic planning services to identify opportunities for tax-efficient transfer pricing structures while maintaining compliance with regulations across all relevant jurisdictions.

Benchmarking Studies

Industry-specific benchmarking analyses comparing your transfer pricing policies with comparable companies in the same sector to establish arm’s length ranges and defend pricing policies.

How Do I Know Which Transfer Pricing Services I Need?

Determining the right transfer pricing services for your business can be challenging. Consider these questions:

  • Do you have international transactions with related parties that require documentation?
  • Is your company required to file Form 3CEB for international transactions?
  • Does your group meet thresholds for Master File or Country-by-Country reporting?
  • Are you facing a transfer pricing assessment or audit by tax authorities?
  • Do you need to establish or review your transfer pricing policies?
  • Are you considering applying for an Advance Pricing Agreement?
  • Do you require assistance with Safe Harbor applications?
  • Are your intercompany agreements aligned with your actual business operations?
  • Do you need help with benchmarking studies for your industry?
  • Are you planning new international structures or arrangements?

If you’re still not sure which services you need, our team can help. We specialize in transfer pricing services, providing personalized solutions for your specific business requirements. Contact us for a consultation.

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Our team of expert Chartered Accountants is ready to address your specific financial needs and challenges. Schedule a consultation today to discuss how we can help you achieve your goals.

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