Indian Transfer
Pricing.
Build a transfer pricing position that works in practice — aligned to your business, supported by evidence and ready for scrutiny.
Transfer pricing is not just a year-end compliance exercise.
The remuneration model, allocation mechanism, contractual terms and supporting documentation should remain consistent with the functions performed, assets employed and risks assumed by the participating entities.
We connect the commercial arrangement, intercompany agreement, actual conduct, financial outcome and supporting evidence into one coherent position.
Small inconsistencies
can become large questions.
One transfer pricing agenda.
Multiple points of support.
From initial policy design through compliance, implementation and dispute resolution.
TP Benchmarking &
Policy Setting
Define a position grounded in the transaction, functions, risks and available evidence.
Discuss ↗Supply Chain &
Transaction Structuring
Policy Implementation
& Monitoring
Documentation &
Compliance
TP Adjustments &
ALP Adherence
Global & Group Level
Compliance Management
CbCR & BEPS
Risk Assessment
Controversy &
Dispute Resolution
APA, MAP &
Safe Harbour
Cloud & AI Based TP Technology Solutions
Technology-enabled workflows for a more consistent transfer pricing process.
From business reality
to defensible evidence.
Six connected steps keep the commercial model, policy, numbers and documentation moving together.
Built for businesses operating across borders.
Our work is designed for finance, tax and business teams managing Indian intercompany arrangements.
Talk to our team ↗When the answer needs
more than a benchmark.
We examine the commercial and financial story behind the number — not just the number itself.
Technical rigour.
Commercial clarity.
Integrated support
Planning, benchmarking, documentation, assessment and litigation connected through one approach.
Transaction-specific analysis
The methodology follows the transaction and evidence — not an automatic template.
Commercial understanding
We evaluate how the business operates, creates value and actually interacts.
Defensible documentation
Functional analysis, contractual framework, economic analysis and financial outcome tell one story.
Implementation focus
Policy is translated into invoicing, accounting entries, reporting and year-end adjustments.
Clear communication
Complex issues are structured for management, auditors and tax authorities.
See the gaps
before scrutiny does.
A year-end report cannot correct an operating model that was not properly implemented. An early review can identify inconsistencies in agreements, pricing, allocations, segmental accounts and supporting evidence.
What should we look at?
- Intercompany transaction profile
- Existing pricing and documentation
- Applicable compliance requirements
- Potential exposure areas
- Immediate and long-term action points
Clear answers to
common TP questions.
Which transactions are covered by Indian transfer pricing provisions?
Indian transfer pricing provisions generally cover international transactions between associated enterprises and specified domestic transactions falling within the applicable statutory scope.
Is benchmarking alone sufficient for transfer pricing compliance?
No. Benchmarking is one component. A defensible position also requires transaction delineation, functional analysis, method selection, reliable financial data, supporting agreements and consistency with actual conduct.
Can multiple intercompany transactions be aggregated?
Transactions may be aggregated where they are closely linked and can be evaluated reliably on a combined basis, supported by the commercial relationship and economic interdependence.
When should an internal comparable be considered?
An internal comparable may be relevant where the tested entity or associated enterprise undertakes a sufficiently comparable transaction with an independent party.
What records should be maintained for intra-group services?
Businesses should retain agreements, invoices, cost workings, allocation keys, correspondence, deliverables and evidence demonstrating the services and commercial benefit.
Should a company consider an APA or Safe Harbour?
The answer depends on transaction nature, value and frequency, functional profile, comparables, expected tax outcome and required certainty.
Have a transfer pricing
question? Let's discuss it.
Share your requirement with our team. We can discuss your transaction profile, documentation, compliance position or current TP challenge.