Transfer Pricing

Transfer pricing regulations in India aim to ensure that transactions between associated enterprises—both international and specified domestic—are conducted at an arm’s length price, i.e., the price that would be charged between unrelated parties in open market conditions. These rules are governed by Sections 92 to 92F of the Income Tax Act, 1961, and are aligned with OECD guidelines.

Our firm provides comprehensive support for transfer pricing compliance, from analysis and benchmarking to documentation and filing.

Scope of services includes:

• Identification of associated enterprises and applicability of transfer pricing provisions

• Analysis of international and specified domestic transactions

• Selection of the most appropriate method for determining arm’s length price (ALP)

• Conducting benchmarking studies using suitable databases and economic analyses

• Preparation of Transfer Pricing Documentation (Local File) as required under Rule 10D

• Support in filing Form 3CEB, certified by a Chartered Accountant, with the Income Tax Department

• Maintenance of contemporaneous documentation and detailed transaction records

• Review and structuring of inter-company agreements to support pricing policies

• Compliance with Master File (Form 3CEAA) and Country-by-Country Report (CbCR) (Form 3CEAC/3CEAD), if applicable

• Representation before tax authorities during transfer pricing audits or assessments

• Support in resolving disputes through the APA (Advance Pricing Agreement) or MAP (Mutual Agreement Procedure) frameworks

• Advisory on transfer pricing implications for cross-border service agreements, royalty/licensing, shared costs, and intra-group financing

The approach ensures that the pricing of related-party transactions is defensible, documented, and compliant with Indian regulations and international standards, thereby reducing the risk of adjustments, penalties, and litigation.