Practical transfer pricing services for multinational groups and Indian companies. We cover policy design, functional analysis, benchmarking, TP documentation, Form 3CEB, Master File and CbCR, Advance Pricing Agreements, and representation from the TPO to the ITAT.
Transfer pricing rules require transactions between related entities, such as sales, services, royalties, loans and guarantees, to be priced at arm's length, as if the parties were independent.
The growing volume of intercompany transactions has made transfer pricing one of the biggest tax risks for multinational groups. India is known for active transfer pricing scrutiny and a high volume of TP disputes. Adjustments can lead to additional tax, interest, penalties and double taxation of the same profits.
We help companies manage this risk with practical transfer pricing solutions that are aligned with their global business and objectives, backed by robust documentation, and defended firmly when challenged.
Benchmarking identifies comparable independent companies or transactions to test whether intercompany pricing is at arm's length.
For Indian tested parties, we search Indian company databases such as Prowess and Capitaline. We apply robust screening, document accept/reject reasons, and compute margins and the arm's length range in line with Indian rules.
Where the foreign entity is the tested party, or for special transactions such as royalties and loans, we use global, public and private comparable databases, including RoyaltyStat, ktMINE, BvD databases such as Amadeus and Orbis, and Thomson Reuters data, directly or with our partner network.
| Requirement | What it involves | Broad applicability |
|---|---|---|
| TP documentation (Local File) | Detailed report on international and specified domestic transactions, FAR analysis and benchmarking | Required where the value of international transactions exceeds the prescribed limit |
| Accountant's Report (Form 3CEB) | CA certification of international and specified domestic transactions | Every entity with such transactions; due before the return due date |
| Master File | Group-level overview of business, intangibles, financing and TP policies | Constituent entities of groups above the prescribed revenue and transaction thresholds |
| Country-by-Country Report (CbCR) | Revenue, profit, tax and activity data for each jurisdiction | Groups with consolidated revenue above the prescribed threshold (aligned with EUR 750 million) |
| Specified domestic transactions | Certain related-party transactions within India | Above the prescribed value threshold |
We prepare TP documentation, issue Form 3CEB, and help prepare and file the Master File and CbCR notifications and reports, in line with OECD BEPS Action 13 and Indian law. Section and form references are moving to the Income-tax Act, 2025, and we manage that transition for you.
Representation before the Transfer Pricing Officer (TPO), the Dispute Resolution Panel (DRP), the Commissioner of Income Tax (Appeals) and the Income Tax Appellate Tribunal (ITAT). See also our tax litigation services.
Support across the APA lifecycle: pre-filing consultation, application, site visits, data gathering, negotiation, finalisation and annual compliance reports.
Help with the Mutual Agreement Procedure to resolve double taxation under tax treaties, and with applying safe harbour rules where eligible.
An APA is an agreement between the taxpayer and the Central Board of Direct Taxes (CBDT). It determines the arm's length price, or the method for determining it, for specified international transactions. It is valid for up to five consecutive years and can be rolled back to up to four earlier years. It binds both the taxpayer and the tax authorities for the covered transactions. APAs can be unilateral, bilateral or multilateral.
CbCR is part of the OECD's BEPS measures against tax avoidance. Large multinational groups report revenue, profits, taxes paid and measures of economic activity for every jurisdiction where they operate. The report is generally filed by the ultimate parent entity in its country of residence. Indian constituent entities have notification and, in some cases, filing obligations.
We map related parties, transactions, value chain and existing policies.
We interview management to document functions, assets and risks.
We select the most appropriate method and tested party, and run benchmarking.
We set or refine pricing, and review results before year-end.
We prepare the TP study, Form 3CEB, Master File and CbCR filings.
We handle TPO audits, DRP and ITAT appeals, APA and MAP.
Share an overview of your related-party transactions. Our TP team will highlight the key risks and next steps, at no cost and with no obligation.
Book a Free Transfer Pricing ConsultationTell us about your group and intercompany transactions. We usually respond within one business day.
