International Transaction Transfer Pricing

Every cross-border dealing between associated enterprises — goods, services, royalty, financing — must be priced at arm's length under Section 92B. We benchmark, document and defend all of it.

Overview

What counts as an international transaction

Under Section 92B, an international transaction is any transaction between two or more associated enterprises, where at least one is a non-resident, involving the purchase/sale of goods, provision of services, lending or borrowing, intangibles, or cost allocation/reimbursement arrangements. If your Indian entity transacts with any related overseas group company, this is almost certainly in scope.

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Who this applies to

Indian subsidiaries of multinational groups, Indian multinationals with overseas operations, and any Indian company transacting with a related non-resident entity above the ₹1 crore threshold.

What We Cover

Every category of international transaction

Purchase & Sale of Goods

Import/export of finished goods, raw materials and components with associated enterprises.

Intra-Group Services

Management fees, shared services, and technical/support service charge-outs.

Royalty & IP

Licensing of brand, technology and know-how, and cost contribution arrangements.

Intercompany Financing

Loans, guarantees and cash-pooling arrangements between group entities.

Our Process

How we approach every engagement

Step 1

Transaction Mapping

Identify and categorise every related-party transaction against Section 92B criteria.

Step 2

Functional Analysis

Characterise functions, assets and risks for each entity in the transaction chain.

Step 3

Method Selection & Benchmarking

Choose the most appropriate method and run a defensible comparability search.

Step 4

Documentation & Filing

Prepare the Local File, TP study report and Form 3CEB, filed on time.

Why Work With Us

Built for scrutiny, not just for filing

Defensible Benchmarking

Comparables selected and documented to withstand TPO challenge.

Every Transaction Type

Goods, services, IP and financing — handled under one roof.

Litigation-Ready

Documentation drafted with an eye on how it will hold up on appeal.

FAQs

Common questions

What threshold triggers TP documentation for international transactions? +

Aggregate international transactions with associated enterprises exceeding ₹1 crore in a financial year require contemporaneous TP documentation and Form 3CEB filing.

Which method is most commonly used for international transactions in India? +

TNMM is the most widely applied method due to the availability of comparable company data, though CUP is preferred where a reliable internal or external comparable exists.

Have cross-border related-party transactions?

Get a free transaction mapping and exposure review.