Service

Transfer Pricing

Getting cross-border transactions right

Getting cross-border transactions right

For businesses operating across borders or within multinational groups, transfer pricing is among the most closely scrutinised areas of taxation. Getting it wrong, even unintentionally, can lead to significant adjustments, penalties and prolonged disputes.

Our transfer pricing practice ensures that inter-company transactions are priced correctly, documented rigorously and defended with confidence. We work with Indian companies with overseas operations, Indian arms of multinational groups and foreign businesses entering India.

Our approach combines fluency in the OECD and Indian frameworks with hands-on benchmarking experience and a practical understanding of how positions are tested before the TPO, the DRP and the ITAT.

Scope of work

What we do for you

  • Transfer pricing policy design and documentation
  • Benchmarking studies and comparability analysis
  • Country-by-Country Reporting compliance
  • Advance Pricing Agreement advisory and filing
  • Transfer pricing audit support and dispute resolution
  • Master File and Local File preparation
  • Permanent establishment risk advisory
  • Drafting and review of inter-company agreements
  • Preparation and filing of Form 3CEB
  • Mutual Agreement Procedure advisory

Who this service is for

Indian subsidiaries of MNEs

TP documentation, Master File and Local File, and audit defence.

Indian multinationals

Outbound TP policy design and CbCR compliance.

Foreign companies entering India

PE risk analysis and inter-company arrangements at the setup stage.

Group treasury & captive operations

Inter-company financing, royalty and management fee structures.

Litigation-stage TP matters

Representation before the TPO, the DRP and the ITAT, and High Court matters together with counsel.

How we work

Our approach

Defensible documentation

We document positions to a standard that holds up before the TPO, the DRP and the ITAT.

Careful benchmarking

The quality of comparables determines outcomes, so we invest in this step.

PE-aware structuring

We always consider transfer pricing and permanent establishment exposure together.

APAs where sensible

For high-value recurring transactions, an APA can offer certainty. We help evaluate and pursue one.

FAQ

Frequently asked questions

Do you prepare the Master File and Local File?

Yes, including benchmarking, disclosures and CbCR filings.

Can you support a transfer pricing audit?

Yes, from the notice response through TPO hearings, the DRP and the ITAT.

Do you advise on APAs?

Yes, including feasibility analysis, pre-filing consultations and unilateral or bilateral APA applications.

Can you assess permanent establishment risk?

Yes. Fixed place, agency, service and digital PE risk analysis is part of our practice.

Let's start a conversation

Whether you have a query, need professional guidance or are looking for a long-term financial partner, reach out and a member of our team will respond promptly.