Transfer Pricing for E-commerce & Retail
Marketplace commissions, fulfilment services and platform technology royalties all cross group-company lines in e-commerce — and India's regulatory-linked structuring makes getting them right doubly important.
Platform economics create layered related-party flows
A single online transaction can touch a marketplace entity, a fulfilment/logistics entity, a technology-licensing entity and a marketing entity — often each a separate group company with its own transfer pricing profile.
Typical structure
A marketplace platform entity earns commission from sellers, a fulfilment entity charges logistics fees, and both may licence technology or brand from an offshore group company.
Where Transfer Pricing applies in E-commerce
Marketplace Commission
Commission or platform-fee structures charged to sellers by the India-facing marketplace entity.
Fulfilment & Logistics
Warehousing and last-mile delivery services charged between group logistics entities.
Digital Marketing Cost Allocation
Global marketing and customer-acquisition costs allocated to the India entity.
Platform Technology Royalty
Licensing fees for platform software, algorithms or brand from a foreign group company.
Payment & Data Services
Cross-charging of payment gateway, data analytics or customer support services.
Private Label Sourcing
Sourcing and pricing arrangements for private-label goods manufactured by group entities.
How these transactions are benchmarked
TNMM
Operating margin benchmarking for the platform or fulfilment entity.
CUP
Commission rate and technology royalty benchmarking.
CPM
Cost-plus benchmarking for fulfilment and logistics services.
Cost Allocation Keys
Defensible allocation keys for shared marketing and technology costs.
A functional map before a pricing model
We first map exactly which group entity performs which function — platform, fulfilment, marketing, technology — then benchmark each against the right comparable set, avoiding one-size-fits-all margins that don't reflect actual risk allocation.
Functional Mapping
Clarify which entity performs which function in the value chain.
Commission Benchmarking
Rate analysis against comparable marketplace models.
Fulfilment Margin Study
Cost-plus benchmarking for logistics entities.
Regulatory Alignment
TP positions consistent with FDI/marketplace-model regulations.
Our E-commerce Transfer Pricing services
Benchmarking Study
Commission, fulfilment and technology royalty analysis.
TP Documentation & 3CEB
Complete filing package across all group entities.
Cost Allocation Advisory
Defensible keys for shared marketing and technology costs.
Audit & Litigation Support
Representation for platform-model TP disputes.
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