Transfer Pricing Services — Every Transaction Type, In-House
We cover the complete transfer pricing lifecycle for companies operating in India: international transactions, specified domestic transactions, documentation, benchmarking, APAs, Safe Harbour, audits, litigation, and international taxation.
International Transaction Transfer Pricing
Under Section 92B of the Income-tax Act, any cross-border transaction between associated enterprises — sale/purchase of goods, provision of services, intangibles, cost allocation, financing or guarantees — must be priced at arm's length. We advise on and document every category:
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 SDT exposure, benchmark intra-group domestic pricing, and prepare the corresponding documentation and Form 3CEB reporting.
Learn more →TP Documentation & Form 3CEB
Contemporaneous, defensible documentation prepared to the standard required under Rule 10D.
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 global databases, we run defensible comparability searches across all prescribed methods.
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 (Master File — consolidated group revenue above ₹500 crore) and Rule 10DB / Section 286 (CbCR — consolidated group revenue above ₹6,400 crore / €750 million), and handle the full filing cycle.
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)
Long-term pricing certainty through India's APA programme — one of the most successful in the world.
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 elections offer a simpler, lower-friction path to TP certainty. We assess eligibility, model the margin impact against your actual results, and file the election.
Learn more →TP Audit & Litigation Support
Our in-house lawyers and senior Chartered Accountants represent clients at every stage of a TP dispute.
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 MAP applications under India's tax treaties, coordinating with foreign competent authorities to reach resolution.
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 — we advise on the full cross-border tax picture for companies operating in India.
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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