Navigating Transfer Pricing Complexities in India
Providing comprehensive transfer pricing documentation, planning, and controversy support for multinational enterprises operating in India.
- Developing arm's length pricing policies documentation
- Preparing required annual transfer pricing documentation
- Conducting benchmarking analysis supporting transfer prices
- Representation support during transfer pricing audits
What is Transfer Pricing?
Transfer Pricing (TP) regulations address the pricing of transactions between related entities within a multinational group (e.g., sale of goods, services, loans, use of intangibles). Indian TP regulations mandate that such transactions must be priced at "arm's length" – reflecting prices that would have been agreed between unrelated parties under similar circumstances.
Documentation
Preparing mandatory annual TP documentation (Local File, Master File, CbCR assistance).
Policy Development
Developing and implementing defensible TP policies.
Analysis
Conducting benchmarking analyses to support arm's length pricing.
Representation
Representing clients during TP audits and appellate proceedings.
Arm's Length Pricing
Ensuring related party transactions are conducted at market prices to prevent tax disputes.
Why TP Compliance is Critical
India's TP regulations are stringent, and non-compliance can result in serious consequences for businesses operating across borders.
- Significant tax adjustments increasing the tax liability.
- Substantial penalties.
- Protracted and costly disputes with tax authorities.
- Potential double taxation if corresponding adjustments are not available elsewhere.
- Robust documentation and a well-reasoned TP policy are crucial for managing tax risk and ensuring certainty in cross-border related-party dealings.
Our Methodical Approach
Policy Development
Assistance in developing practical and compliant TP policies that align with your business operations while meeting regulatory requirements.
Functional Analysis
Thorough functional analysis (FAR) and rigorous benchmarking studies to identify comparable transactions and establish arm's length pricing.
Documentation
Preparation of comprehensive, audit-ready TP documentation that meets all regulatory requirements and provides strong support for your pricing policies.
Audit Defense
Strong, technically sound representation during TP audits and controversy, leveraging our experience to defend the client's position effectively within the legal framework.
Ensure Compliant and Defensible Transfer Pricing
Our team of transfer pricing specialists combines technical expertise with practical experience to help you navigate India's complex TP regulations while minimizing tax risks and ensuring compliance.