Transfer Pricing for Startups & Technology Groups
As Indian startups build cross-border holding structures and scale internationally, transfer pricing questions arrive earlier than most founders expect. We help you get ahead of them.
Growth structures create transfer pricing exposure fast
A "flip" to an overseas holding company, ESOP cost recharges, intercompany service agreements and intra-group loans are all standard parts of a scaling startup's structure — and all fall squarely within the transfer pricing net well before most founders think to plan for it.
Typical structure
An Indian operating subsidiary provides services to (or receives services from) an overseas holding/parent entity, with ESOP costs, IP and intercompany funding flowing across the structure as the group scales.
Where Transfer Pricing applies in Startups
Cross-Border Holding ("Flip") Structures
Intercompany service arrangements once an Indian entity becomes a subsidiary of an overseas holding company.
ESOP Cost Recharge
Recharge of employee stock option costs from the foreign parent to the Indian subsidiary.
Intercompany Loans & Convertibles
Funding arrangements between group entities, including convertible instruments.
IP & Brand Transfer
Transfer or licensing of technology/brand IP as the group restructures for international scale.
Shared Technology Services
Platform, engineering or data services charged between group entities.
Pre-Funding TP Readiness
Documentation gaps that surface during due diligence ahead of Series B/C funding rounds.
How these transactions are benchmarked
TNMM
Margin benchmarking for intercompany service arrangements.
CUP
ESOP cost recharge and IP valuation benchmarking.
Valuation-Based Methods
Independent IP valuation for early-stage cross-border transfers.
Interest Rate Benchmarking
Market-based rates for intercompany loans and convertible instruments.
TP-ready before it's mandatory, not after it's a problem
We build a lightweight, scalable TP documentation framework early — before thresholds make it mandatory — so it's ready to withstand due diligence in your next funding round and won't need to be reconstructed under pressure.
Early TP Health Check
Identify exposure before it becomes a compliance gap.
ESOP Recharge Benchmarking
Defensible cost-recharge pricing.
IP Valuation Support
Independent valuation for cross-border IP transfers.
Funding-Round Ready
Documentation built to survive investor due diligence.
Our Startup & Technology Group Transfer Pricing services
TP Health Check
Quick-turnaround exposure assessment for scaling companies.
Documentation Setup
Lightweight, scalable Local File and 3CEB-ready framework.
ESOP & IP Advisory
Cost recharge and valuation support.
Ongoing Compliance Calendar
Annual documentation refresh as thresholds and structures evolve.
Scaling across borders from India?
Get a free TP health check before your next funding round.