Transfer Pricing Services — Every Transaction Type, In-House
Transfer Pricing India provides ten core services covering the full TP lifecycle: international and specified domestic transaction pricing, TP documentation and Form 3CEB, benchmarking, Master File and CbCR, Advance Pricing Agreements, Safe Harbour elections, audit and litigation support, MAP, and international taxation.
Our transfer pricing services in India are designed for Indian companies, multinational subsidiaries and global groups that need consistent support from transaction planning and compliance through audit defence and dispute resolution.
International Transaction Transfer Pricing
Under Section 92B of the Income-tax Act, any cross-border transaction between associated enterprises — including the sale or purchase of goods, provision of services, intangibles, cost allocations, financing arrangements or guarantees — must be priced at arm's length. We review the commercial substance of each transaction, identify the most appropriate method, test the pricing and prepare contemporaneous support that aligns with contracts and actual conduct.
Our international transaction work also covers business restructurings, captive service models, limited-risk distribution, contract manufacturing, management charges and intercompany financing. The objective is to create a consistent position that can be explained clearly in the TP study, Form 3CEB and any later audit proceedings.
Learn more →Purchase & Sale of Goods
Import/export of finished goods, raw materials and components between related entities.
Intra-Group Services
Management fees, shared services, technical and support service charge-outs.
Royalty & IP Transactions
Licensing of brand, technology, know-how and cost contribution arrangements.
Intercompany Financing
Loans, guarantees, cash-pooling arrangements and interest rate benchmarking.
Specified Domestic Transactions (SDT)
Payments to related domestic parties, transactions with entities enjoying profit-linked tax holidays (Sec 80-IA etc.), and other SDTs under Section 92BA where the aggregate value exceeds ₹20 crore.
Specified Domestic Transactions
Even purely domestic related-party dealings can trigger TP compliance in India. We identify specified domestic transaction exposure, map the relevant connected parties, benchmark intra-group pricing and prepare the corresponding documentation and Form 3CEB reporting.
Our review focuses on the statutory threshold, the nature of the payment, the relationship between the entities and whether the transaction affects units claiming profit-linked deductions. This helps management avoid missed disclosures and maintain a clear audit trail for domestic TP positions.
Learn more →TP Documentation & Form 3CEB
Our TP documentation services cover contemporaneous, defensible records prepared to the standard required under Rule 10D. We connect the FAR analysis, industry overview, economic analysis, agreements, invoices and financial data so the documentation reflects how the business actually operates.
The deliverable set may include the Local File, TP study report, transaction schedules, benchmarking annexures, management representations and Form 3CEB support. Each report is designed to be clear enough for internal teams and robust enough for tax-authority review.
Learn more →Local File / TP Study Report
Entity-level functional, industry and economic analysis supporting the pricing of each transaction category.
Form 3CEB (Accountant's Report)
Statutory reporting of all international and specified domestic transactions, certified and filed on time.
Policy Documents & Agreements
Intercompany agreements and TP policy documents aligned with actual conduct and OECD guidance.
Comparability & Benchmarking Analysis
Using Prowess, Capitaline and relevant global databases, we run defensible comparability searches across all prescribed methods. The work includes tested-party selection, profit-level indicator analysis, quantitative filters, qualitative review, rejection matrices and multi-year data where appropriate.
TNMM is applied most often in India because reliable net-margin data is widely available, but CUP remains preferable where a sufficiently reliable internal or external comparable exists. RPM, CPM, PSM and the Other Method are evaluated according to the transaction profile rather than used mechanically.
Learn more →CUP
Comparable Uncontrolled Price method for goods, royalties and financial transactions.
RPM / CPM
Resale Price & Cost Plus Methods for distribution and manufacturing set-ups.
TNMM
Transactional Net Margin Method — the most widely applied method in Indian TP.
PSM & Other Method
Profit Split for integrated/unique transactions; Other Method where prescribed methods don't fit.
Master File & Country-by-Country Reporting (CbCR)
We assess applicability thresholds under Rule 10DA for Master File compliance and Rule 10DB read with Section 286 for Country-by-Country Reporting, then manage the complete Master File CbCR filing cycle for Indian constituent entities.
Our support includes group-data collection, reconciliation with consolidated financial information, entity-role mapping, intimation filings, Form 3CEAA preparation and coordination with overseas parent teams. The aim is to maintain consistency between the Indian Local File, group Master File and CbCR disclosures.
Learn more →Master File (Form 3CEAA)
Group-wide business, intangibles, financing and financial information reporting.
CbCR (Forms 3CEAC / 3CEAD)
Intimation and country-by-country report filing for Indian constituent entities of large MNC groups.
Advance Pricing Agreements (APA)
We support Advance Pricing Agreement India applications from feasibility analysis and pre-filing consultation through economic modelling, filing, negotiation, annual compliance and renewal. An APA can provide multi-year certainty over the method, tested party, comparables, margins and critical assumptions for covered transactions.
Our team handles unilateral, bilateral and multilateral cases, including rollback analysis where available. We also coordinate with treaty-partner advisors so the factual position and economic narrative remain consistent across competent-authority discussions.
Learn more →Unilateral APA
Agreement with the Indian tax authority alone, typically the fastest route to certainty.
Bilateral APA
Negotiated jointly with a treaty partner's competent authority to eliminate double taxation risk.
Multilateral APA
Covering transactions across multiple jurisdictions in a single coordinated agreement.
Safe Harbour Rules Advisory
Eligibility assessment and election support under Rule 10TA–10TG for IT/ITES, KPO, contract R&D, auto components, intra-group loans and corporate guarantees — reducing audit risk with pre-agreed margins.
Safe Harbour Rules
Where eligible, Safe Harbour Rules India can offer a simpler, lower-friction route to TP certainty. We assess transaction eligibility, test the prescribed operating margins or interest benchmarks against actual performance and compare the result with a conventional benchmarking approach.
Our support covers election strategy, documentation, prescribed forms and ongoing compliance. Management receives a clear view of the certainty benefit, potential tax cost and practical trade-offs before making the election.
Learn more →TP Audit & Litigation Support
Our transfer pricing audit support is delivered by senior Chartered Accountants and in-house lawyers who represent clients at every stage of a TP dispute. We prepare factual submissions, economic rebuttals, comparable-company analyses, case-law notes and hearing briefs tailored to the issue under review.
The same team can support TPO assessment, DRP objections, CIT(A) appeals, ITAT proceedings and secondary-adjustment matters. This continuity reduces the risk of inconsistent arguments between documentation, assessment and appellate stages.
Learn more →TPO Assessment
Representation and submissions during reference under Section 92CA.
DRP Objections
Filing and arguing objections before the Dispute Resolution Panel.
CIT(A) & ITAT
Appellate representation with detailed factual and legal briefs.
Secondary Adjustments
Advisory on Section 92CE secondary adjustment and repatriation implications.
Mutual Agreement Procedure (MAP)
Where double taxation arises from a TP adjustment, we prepare and pursue Mutual Agreement Procedure applications under India's tax treaties. The work includes eligibility review, issue framing, quantification of double taxation, preparation of supporting records and coordination with foreign competent authorities.
We also align the MAP strategy with any domestic appeal, APA process or related overseas proceeding. The goal is a practical resolution that removes or reduces double taxation while preserving consistency across jurisdictions.
Learn more →Cross-Border Coordination
We work directly with your overseas tax advisors and treaty-partner authorities through to case closure.
International Taxation for Companies in India
Transfer pricing rarely stands alone. Our international taxation services India practice connects TP analysis with permanent-establishment risk, withholding tax, treaty interpretation, thin capitalisation, profit attribution and cross-border structuring.
This integrated approach is useful when a transaction creates both pricing and broader tax consequences. We help clients evaluate the complete position before implementation, document the rationale and coordinate compliance across legal entities and jurisdictions.
Learn more →PE Exposure & Attribution
Permanent establishment risk assessment and profit attribution analysis.
Withholding Tax & DTAA
Treaty analysis, Form 15CA/15CB and lower/nil withholding certificate applications.
Thin Capitalisation (Sec 94B)
Interest deduction limitation analysis for excess interest paid to associated enterprises.
Cross-Border Structuring
Tax-efficient structuring for inbound investment, outbound investment and business restructuring.
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