Transfer Pricing
Service
Transfer Pricing
Getting Cross-Border Transactions Right
For businesses operating across borders or within multinational groups, transfer pricing is one of the most scrutinised areas of taxation globally. Getting it wrong — even unintentionally — can result in significant tax adjustments, penalties, and prolonged disputes.
Our transfer pricing practice ensures your inter-company transactions are priced correctly, documented rigorously, and defended confidently. We work with Indian companies with overseas operations, with Indian arms of multinational groups, and with foreign businesses entering India.
Our approach combines technical fluency with the OECD and Indian frameworks alongside hands-on benchmarking experience — and a litigation-aware view shaped by our partners' work before the TPO and ITAT.
What we do for you:
Transfer pricing policy design & documentation
Benchmarking studies & comparability analysis
Country-by-Country Reporting (CbCR) compliance
Advance Pricing Agreement (APA) advisory & filing
Transfer pricing audit support & dispute resolution
Master File & Local File preparation
Advisory on permanent establishment (PE) exposure
Inter-company agreements drafting & review
Form 3CEB preparation & filing
Mutual Agreement Procedure (MAP) advisory
Who This Service Is For
Our Approach
Documentation You Can Defend
We document positions to a standard that holds up under TPO, DRP, and ITAT scrutiny.
Benchmarking, Done Properly
Quality of comparable selection determines outcomes. We invest in this step rather than rushing it.
PE-Aware Structuring
Transfer pricing without PE awareness is incomplete. We always view both together.
APA Where Sensible
For high-value, recurring transactions, an APA can be the cleanest answer. We help evaluate and pursue.
A full spectrum of financial, tax, audit, and advisory services — designed to meet the needs of businesses and individuals at every stage of growth.
FAQ
Frequently Asked Questions
Do you prepare Master File and Local File?
Yes — including consolidated benchmarking, disclosures, and CbCR filings.
Can you support a transfer pricing audit?
Yes — from notice response through TPO hearings, DRP and ITAT representation.
Do you advise on APAs?
Yes — feasibility analysis, pre-filing consultations, and unilateral / bilateral APA filings.
Can you help assess permanent establishment risk?
Yes — operational, agency, service and digital PE risk analyses are part of our practice.
Contact Us
Let's Start a Conversation
Whether you have a query, need professional guidance, or are looking for a long-term financial partner, we're here to help. Reach out to us and a member of our team will get back to you promptly.
A full-service Chartered Accountancy firm headquartered in Ahmedabad, India - delivering integrated tax, audit, advisory and compliance services since 1996.
Registered with the Institute of Chartered Accountants of India (ICAI).
