Transfer Pricing for Healthcare & Diagnostics
As hospital and diagnostic chains scale into multi-city, multi-country groups, management fees, technology licences and shared services all need arm's-length pricing.
Group hospital models create recurring related-party charges
Hospital and diagnostics groups promoted or supported by a foreign holding structure typically centralise management, procurement and medical-technology functions — each cross-charged to operating entities and each subject to transfer pricing scrutiny.
Typical structure
A hospital or diagnostics chain pays a management fee to its foreign promoter group and licenses medical technology or accreditation know-how, while sharing corporate services across group entities.
Where Transfer Pricing applies in Healthcare
Management Fees
Fees paid to a foreign promoter or holding group for management and governance support.
Medical Technology Licensing
Licensing diagnostic equipment technology, protocols or accreditation frameworks.
Cross-Border Referral Fees
Referral or second-opinion arrangements between group hospitals across countries.
Shared Corporate Services
Centralised procurement, HR, IT and finance functions cross-charged group-wide.
Brand Licensing
Royalty for use of a recognised hospital or diagnostics brand name.
Clinical Training Programmes
Cost-sharing for cross-border medical training and skill development.
How these transactions are benchmarked
CPM / TNMM
Management fee and shared-service margin benchmarking.
CUP
Medical technology and brand royalty rate benchmarking.
Benefit Test Analysis
Demonstrating genuine benefit received to support management fee deductibility.
Cost Allocation Keys
Defensible allocation of shared corporate service costs.
Management fees backed by a genuine benefit test
We document precisely what services are received for each management fee or licence payment, benchmark the fee against comparable healthcare management agreements, and build cost-allocation keys that hold up to scrutiny.
Management Fee Benchmarking
Comparable agreements and benefit-test documentation.
Technology Royalty Analysis
Medical technology and accreditation licensing rates.
Shared Service Costing
Defensible allocation of group corporate service costs.
Structuring Advisory
TP-ready structuring for multi-city hospital group expansion.
Our Healthcare Transfer Pricing services
Benchmarking Study
Management fee, royalty and shared-service margin analysis.
TP Documentation & 3CEB
Complete Local File and Accountant's Report.
Benefit Test Documentation
Evidence packages supporting management fee deductibility.
Audit & Litigation Support
Representation before the TPO, DRP, CIT(A) and ITAT.
Paying management fees or licensing medical technology?
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