Transfer Pricing

Strategic transfer pricing solutions for compliant and tax-efficient cross-border transactions

Global Transfer Pricing Expertise

Transfer pricing regulations have become increasingly complex with BEPS initiatives and country-by-country reporting requirements. Our Transfer Pricing services provide comprehensive support in documentation, compliance, planning, and dispute resolution to ensure arm's length pricing and regulatory compliance.

With experience across industries and geographies, we help multinational enterprises manage transfer pricing risks and optimize their global tax position.

200+
TP Studies Completed
50+
Countries Covered
100+
APA Applications
95%
Audit Success Rate

Our Transfer Pricing Services

TP Documentation

Comprehensive transfer pricing documentation as per regulatory requirements

  • Master file preparation
  • Local file documentation
  • Form 3CEB compliance
  • Benchmarking studies

CbCR Compliance

Country-by-Country Reporting for multinational groups

  • CbCR preparation and filing
  • Global documentation coordination
  • Multi-jurisdiction compliance
  • BEPS Action Plan implementation

TP Planning

Strategic transfer pricing planning for tax efficiency

  • Pricing policy design
  • Value chain analysis
  • Intangible property strategies
  • Business restructuring support

APA Services

Advance Pricing Agreement applications and negotiations

  • Unilateral APA applications
  • Bilateral/Multilateral APAs
  • APA renewal support
  • Compliance monitoring

TP Audit Support

Expert representation during transfer pricing assessments

  • Assessment representation
  • Notice response preparation
  • Documentation review
  • Negotiation support

Litigation Support

Strategic support for transfer pricing disputes

  • Appeal filing and representation
  • DRP proceedings
  • MAP resolution support
  • Expert witness services

Transfer Pricing Methods

CUP

Comparable Uncontrolled Price

Direct comparison of prices charged in controlled transactions with those in comparable uncontrolled transactions

RPM

Resale Price Method

Based on resale price to independent party, reduced by appropriate gross profit margin

CPM

Cost Plus Method

Costs incurred plus an appropriate mark-up to ensure arm's length pricing

PSM

Profit Split Method

Combined profits split between associated enterprises based on economic functions performed

TNMM

Transactional Net Margin

Net profit margin relative to appropriate base that taxpayer realizes from controlled transaction

Other

Other Methods

Any other method prescribed by CBDT or approved by tax authorities for specific circumstances

Transactions We Cover

Goods Trading

Services

Loans & Guarantees

Intangibles (IP)

Manufacturing

Capital Assets

Business Restructuring

Cost Sharing

Need Transfer Pricing Expertise?

Let's discuss how we can help you achieve compliance and optimize your global tax position