Transfer Pricing for Healthcare & Diagnostics

As hospital and diagnostic chains scale into multi-city, multi-country groups, management fees, technology licences and shared services all need arm's-length pricing.

Why It Matters

Group hospital models create recurring related-party charges

Hospital and diagnostics groups promoted or supported by a foreign holding structure typically centralise management, procurement and medical-technology functions — each cross-charged to operating entities and each subject to transfer pricing scrutiny.

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Typical structure

A hospital or diagnostics chain pays a management fee to its foreign promoter group and licenses medical technology or accreditation know-how, while sharing corporate services across group entities.

Common Cases

Where Transfer Pricing applies in Healthcare

Management Fees

Fees paid to a foreign promoter or holding group for management and governance support.

Medical Technology Licensing

Licensing diagnostic equipment technology, protocols or accreditation frameworks.

Cross-Border Referral Fees

Referral or second-opinion arrangements between group hospitals across countries.

Shared Corporate Services

Centralised procurement, HR, IT and finance functions cross-charged group-wide.

Brand Licensing

Royalty for use of a recognised hospital or diagnostics brand name.

Clinical Training Programmes

Cost-sharing for cross-border medical training and skill development.

Applicable TP Methods

How these transactions are benchmarked

CPM / TNMM

Management fee and shared-service margin benchmarking.

CUP

Medical technology and brand royalty rate benchmarking.

Benefit Test Analysis

Demonstrating genuine benefit received to support management fee deductibility.

Cost Allocation Keys

Defensible allocation of shared corporate service costs.

Our Solution

Management fees backed by a genuine benefit test

We document precisely what services are received for each management fee or licence payment, benchmark the fee against comparable healthcare management agreements, and build cost-allocation keys that hold up to scrutiny.

Management Fee Benchmarking

Comparable agreements and benefit-test documentation.

Technology Royalty Analysis

Medical technology and accreditation licensing rates.

Shared Service Costing

Defensible allocation of group corporate service costs.

Structuring Advisory

TP-ready structuring for multi-city hospital group expansion.

How We Help

Our Healthcare Transfer Pricing services

Benchmarking Study

Management fee, royalty and shared-service margin analysis.

TP Documentation & 3CEB

Complete Local File and Accountant's Report.

Benefit Test Documentation

Evidence packages supporting management fee deductibility.

Audit & Litigation Support

Representation before the TPO, DRP, CIT(A) and ITAT.

Paying management fees or licensing medical technology?

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