Advisory · Transfer Pricing
Price intercompany deals
so India can't challenge them.
Transfer pricing governs how your India entity prices transactions with its foreign parent or group — services, royalties, financing, and goods. India requires those prices to be at arm's length, supported by a contemporaneous local file and certified in Form 3CEB. We design the policy, benchmark it, document it, file it, and defend it if it's examined.
Every payment between your India subsidiary and the group is a transfer-pricing position the tax authority can challenge. We make those prices defensible — benchmarked, documented, and consistent with your global policy — so an adjustment, penalties, and double tax never come as a surprise.
- Arm's length
- Benchmarked & defensible
- Full documentation
- Local file & Form 3CEB
- Audit-ready
- Built to survive scrutiny
Where TP exposure builds
Every payment to your parent is a transfer-pricing risk.
- Arm's length
Can you prove your intercompany prices are arm's length?
Management fees, royalties, cost-sharing, and intra-group services must be priced as if between unrelated parties. Without benchmarking, the tax authority sets the price for you.
- Documentation
Is your transfer-pricing documentation actually in place?
India requires a local file, an accountant's report (Form 3CEB), and master/country-by-country filing above thresholds. Missing or weak documentation invites adjustments and penalties.
- Adjustments
What happens if India re-prices your transactions?
A TP adjustment increases taxable income, adds interest and penalties, and can trigger economic double taxation across two countries unless it's defended properly.
- Consistency
Do your India and group TP positions match?
A policy that's documented one way at HQ and applied another way in India is the easiest thing for an auditor to unwind. The two sides have to be consistent.
Transfer pricing isn't an annual form — it's a position you take on every intercompany transaction. Weak benchmarking, missing documentation, and India-versus-group inconsistency are exactly what tax officers look for, and each one converts into an adjustment plus interest and penalties.
What's included
Transfer pricing, handled end to end.
Policy, benchmarking, documentation, filing, and defense — handled by one in-house team of chartered accountants.
Transfer-pricing policy & planning
We design an intercompany pricing policy for your India entity — services, royalties, cost allocation, financing — that is commercially sensible, tax-efficient, and defensible.
- Intercompany pricing policy
- Method selection
- Tax-efficient, compliant design
Benchmarking & economic analysis
We run comparability and benchmarking studies using accepted databases to establish arm's-length ranges that stand up to the Indian tax authority.
- Comparability analysis
- Database benchmarking
- Arm's-length range
Local file & TP documentation
We prepare the contemporaneous local file and supporting documentation India requires, aligned with your group master file and global policy.
- Contemporaneous local file
- Master-file alignment
- Supporting workpapers
Form 3CEB & statutory filing
We issue the accountant's report in Form 3CEB and complete the transfer-pricing filings, including master-file and country-by-country obligations where they apply.
- Form 3CEB certification
- Master file / CbCR where applicable
- On-time statutory filing
Audit & dispute support
If your transactions are examined, we represent your position before the tax officer and at appeal, and advise on APAs and MAP to resolve disputes and avoid double tax.
- TP assessment representation
- APA & MAP guidance
- Double-tax resolution
Annual review & true-up
Each year we test outcomes against the policy, true up where needed, and refresh benchmarking so your position stays current as the business changes.
- Annual outcome testing
- Year-end true-up
- Refreshed benchmarks
How we work
From intercompany flows to a defensible position.
We identify every intercompany flow between your India entity and the group — services, royalties, financing, goods — and the functions and risks behind each.
We select the right method, run benchmarking, and set defensible arm's-length pricing aligned to your global policy.
We prepare the local file and supporting documentation and issue the Form 3CEB accountant's report on time.
We monitor outcomes, true up annually, and represent your position if the transactions are examined.
FAQ
India transfer pricing, answered.
Transfer pricing is the set of rules governing how related companies in different tax jurisdictions price transactions between themselves — intra-group services, royalties, financing, and goods. In India, transfer-pricing rules apply to any 'international transaction' between associated enterprises (for example, an India subsidiary and its foreign parent). The prices must be at arm's length — what unrelated parties would have agreed — and the position must be documented and certified. It applies regardless of the transaction size once there is a cross-border related-party dealing.
Get your transfer pricing right the first time.
Tell us about your intercompany transactions with India. We'll design and benchmark the pricing, prepare the documentation and Form 3CEB, and keep the position defensible.
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