Transfer Pricing for Automotive & Auto Components

From component export pricing to technology royalties on global platforms, we help auto manufacturers and ancillary suppliers keep every related-party transaction defensible.

Why It Matters

Global platforms, local manufacturing

Indian auto component makers are frequently embedded in global OEM supply chains — exporting parts to a parent, licensing designs, and importing kits — all priced under the watchful eye of both the TPO and the customs authorities.

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Typical structure

A component manufacturer exports to its global OEM parent under a long-term supply agreement, pays royalty for design/technology, and is benchmarked on manufacturing margin.

Common Cases

Where Transfer Pricing applies in Automotive

Component Export

Manufacturing and exporting auto parts to a global OEM parent or group distribution entity.

Technology & Design Royalty

Licensing platform designs, engineering know-how or brand use from the parent.

CKD/SKD Kit Imports

Importing completely/semi-knocked-down kits from a related overseas manufacturer.

Safe Harbour Eligibility

Core and non-core auto component manufacturing eligible for pre-agreed Safe Harbour margins.

Tooling & R&D Cost Recovery

Cost contribution for shared tooling development or vehicle R&D programmes.

After-Sales & Warranty

Cross-charging of warranty and after-sales support costs within the group.

Applicable TP Methods

How these transactions are benchmarked

TNMM

Manufacturing margin benchmarking against comparable component makers.

CUP

Royalty rates and import pricing for kits and components.

Safe Harbour (Rule 10TA)

Pre-agreed margins for core/non-core auto component manufacturing and export.

CPM

Cost-plus benchmarking for tooling and R&D cost recovery arrangements.

Our Solution

Margins that hold up against both the TPO and customs

We benchmark manufacturing margins against genuinely comparable auto ancillary companies, test Safe Harbour eligibility against your actual segment classification, and align transfer pricing and customs valuation positions to avoid contradictory filings.

Manufacturing Benchmarking

Segment-specific comparable company analysis.

Safe Harbour Assessment

Core vs. non-core classification and margin modelling.

Royalty Defensibility

Technology licence rate benchmarking.

Customs Alignment

Consistent related-party pricing across TP and customs.

How We Help

Our Automotive Transfer Pricing services

Benchmarking Study

Manufacturing margin analysis against auto ancillary comparables.

Safe Harbour Election

Eligibility review and filing under Rule 10TA.

TP Documentation & 3CEB

Complete Local File and Accountant's Report each year.

APA for OEM Supply

Long-term certainty for recurring component supply arrangements.

Supplying a global OEM from India?

Get your manufacturing margin and Safe Harbour position reviewed, free.