Transfer Pricing for Real Estate & Infrastructure
Multi-SPV group structures common in real estate and infrastructure create dense webs of intercompany contracts, financing and service fees — every one needing arm's-length pricing.
Project-based structures, project-based transactions
Real estate and infrastructure groups typically operate through multiple special purpose vehicles (SPVs), each transacting with related development, financing and engineering entities within the same group — a structure that multiplies the number of related-party transactions requiring documentation.
Typical structure
A project SPV receives construction and project-management services from a related developer entity, financing from a related NBFC or holding company, and design services from a foreign engineering affiliate.
Where Transfer Pricing applies in Real Estate & Infrastructure
Project Management Contracts
Construction and project-management fees between related developer and SPV entities.
Development Rights Transfer
Transfer of development rights or land parcels between related SPVs.
Intercompany Financing
Loans and guarantees for infrastructure project funding within the group.
Engineering & Design Fees
Technical design services from a foreign engineering affiliate.
Facilities Management
Cross-charging of facilities and property management services.
Brand Licensing
Royalty for using a group real estate or hospitality brand name.
How these transactions are benchmarked
CPM
Project management and construction fee benchmarking.
CUP
Interest rate benchmarking for intercompany project financing.
TNMM
Margin benchmarking for engineering and design service entities.
Valuation-Based Methods
Independent valuation support for development rights transfers.
SPV-by-SPV documentation, not a single group-wide file
We map related-party transactions at each SPV level, benchmark project management fees and financing rates against comparable market data, and keep documentation aligned across the group's often-complex holding structure.
SPV-Level Mapping
Transaction inventory across every project entity.
Financing Rate Benchmarking
Market-based interest rates for intra-group project funding.
Project Fee Benchmarking
Comparable construction/PM fee analysis.
Group Structuring Advisory
TP-aware structuring for new project SPVs.
Our Real Estate & Infrastructure Transfer Pricing services
Benchmarking Study
Project management, financing and design fee analysis.
TP Documentation & 3CEB
SPV-level Local Files and Accountant's Reports.
Financing Structuring
Interest rate and guarantee fee advisory for project funding.
Audit & Litigation Support
Representation across multi-SPV group disputes.
Running a multi-SPV real estate or infra group?
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