Arm's length pricing, fully defensible
Transfer Pricing
Our transfer pricing practice provides Big-4 quality documentation, benchmarking studies, and litigation support — ensuring your intercompany transactions are priced correctly, documented rigorously, and defensible before tax authorities.
What We Cover
- Transfer pricing study & documentation
- Benchmarking analysis (TNMM, CUP, RPM)
- Form 3CEB certification
- APA (Advance Pricing Agreement) support
- TP audit defence and litigation
- Country-by-country reporting (CbCR)
Our Transfer Pricing Services Include
Transfer Pricing Study
Comprehensive TP study including functional analysis, economic analysis, and selection of the most appropriate method (TNMM, CUP, RPM, PSM).
Form 3CEB Certification
Accountant’s report under Section 92E certifying the arm’s length nature of international transactions.
Master File & Local File
BEPS-aligned Master File (Form 3CEAA) and Local File documentation for multinational groups.
Country-by-Country Reporting
CbCR filing (Form 3CEAD) for groups with consolidated revenue exceeding ₹550 crore.
APA Support
Advance Pricing Agreement applications (unilateral and bilateral) to obtain certainty on TP methodology.
TP Audit Defence & Litigation
Representation before TPO, Dispute Resolution Panel (DRP), ITAT, and High Court in TP disputes.
Key Service Features
TP Documentation
Comprehensive transfer pricing study and master/local file preparation.
Benchmarking
Arm's length price determination using TNMM, CUP, RPM, and PSM methods.
Form 3CEB
Accountant's report certification under Section 92E of Income Tax Act.
TP Litigation
Representation before TPO, DRP, ITAT, and High Court.
Who We Serve
Our Clients
- Wholly-owned Indian subsidiaries of foreign MNCs
- Indian companies with overseas subsidiaries
- GCC/Captive centres in India
- Companies with inter-company service agreements
- Entities with royalty or IP licensing arrangements
- Companies facing TPO audits
Frequently Asked Questions
Which transactions require transfer pricing documentation?
All international transactions between associated enterprises are subject to transfer pricing regulations including sale or purchase of goods, provision of services, loans and guarantees, IP licensing, cost sharing, and business restructuring. Specified Domestic Transactions exceeding Rs.20 crore also require compliance. Form 3CEB is mandatory when aggregate international transactions exceed Rs.1 crore.
What transfer pricing methods are prescribed in India?
India prescribes six methods: Comparable Uncontrolled Price, Resale Price Method, Cost Plus Method, Transactional Net Margin Method, Profit Split Method, and Other Method. TNMM is the most widely used due to data availability. The method providing the most reliable measure of arm's length price must be applied.
What is Form 3CEB and when must it be filed?
Form 3CEB is the accountant's report certifying that international and specified domestic transactions have been undertaken at arm's length and that prescribed documentation has been maintained. It must be filed electronically by a Chartered Accountant along with the income tax return by 31 October. Late filing attracts a penalty of Rs.1 lakh.
What documentation must be maintained for transfer pricing compliance?
Documentation must be contemporaneous and include a description of the business and industry, details of international transactions, AE relationship analysis, functional analysis covering functions assets and risks, selection and application of the most appropriate method, comparable search and benchmarking analysis, and economic analysis. Documentation must be maintained for 8 years.
What is an Advance Pricing Agreement and what are the benefits?
An APA is a binding agreement with the CBDT that pre-determines the arm's length price for specific transactions for up to 5 future years with rollback available for 4 preceding years. Benefits include elimination of transfer pricing litigation, certainty of tax outcomes, prevention of double taxation in bilateral APAs, and significantly reduced documentation burden during the APA period.
What penalties apply for transfer pricing non-compliance?
Penalties include 2% of transaction value for failure to maintain or furnish prescribed documentation, Rs.1 lakh for failure to furnish Form 3CEB, 50% of tax on adjusted income if the adjustment arises from non-maintenance of documentation, and 200% of tax if the transaction is not reported. Transfer pricing adjustments also attract interest under Sections 234B and 234C.
What is secondary adjustment and how does it affect our group?
Secondary adjustment under Section 92CE applies when a primary transfer pricing adjustment exceeds Rs.1 crore. The differential is treated as an advance by the Indian entity to the AE and imputed interest is added to income. To avoid secondary adjustments the excess profit must be repatriated to India within the prescribed period.