Transfer Pricing
Arm's length pricing that stands up to scrutiny. We design, document and defend intercompany arrangements across India and the OECD framework, so your global policy and your local filings tell the same story.
What we do
Transfer Pricing Advisory
Designing group-wide TP policies, characterising entities on a functions-assets-risks basis, selecting the tested party and setting prices for goods, services, royalties, financing and cost-sharing arrangements.
Intercompany Agreements
Drafting and reviewing intercompany agreements so that legal form, operational conduct and the TP policy are consistent and defensible.
India Local File / TP Study Report
Preparing Rule 10D-compliant documentation and supporting the Form 3CEB accountant's report, with FAR analysis, method selection and economic analysis.
Benchmarking Analysis
Searches on leading global and Indian databases for tangible goods, services, intangibles and financial transactions (loans, guarantees, cash pooling), with multi-year margin computation and interquartile ranges.
Master File
Preparing or updating the group Master File and filing Form 3CEAA (Part A and Part B) and Form 3CEAB in India.
Country-by-Country Reporting
Preparing OECD-compliant CbC reports, filing Form 3CEAC / 3CEAD / 3CEAE and converting data into the prescribed OECD XML schema.
IP Structuring and DEMPE Analysis
Mapping development, enhancement, maintenance, protection and exploitation functions to allocate intangible returns correctly and support IP migration or licensing decisions.
Safe Harbour and APA Support
Evaluating eligibility for India's safe harbour rules and supporting unilateral or bilateral Advance Pricing Agreement applications for long-term certainty.
Audit Defence and Litigation
Representation before the Transfer Pricing Officer, DRP, CIT(A) and ITAT, including MAP support under tax treaties.
BEPS and Pillar Two
Impact assessments and compliance support for OECD BEPS actions, including Pillar Two GloBE calculations.