Transfer Pricing Services

Transfer pricing governs how transactions between related or associated enterprises, whether across borders or within India, are priced for tax purposes, and requires that such pricing reflect what unrelated parties would have agreed to under comparable circumstances. Indian transfer pricing regulations mandate detailed documentation, benchmarking, and reporting for international transactions and specified domestic transactions, and non-compliance or an indefensible pricing position can lead to substantial adjustments, penalties, and disputes that persist for years.

Why This Matters

Tax authorities routinely select related-party transactions for scrutiny, and the burden of proving that pricing is at arm's length rests squarely on the taxpayer. Businesses that do not maintain robust, contemporaneous documentation often find themselves unable to defend positions taken years earlier, resulting in adjustments that increase taxable income, attract interest, and in some cases invite penalty proceedings.

How We Help

Benchmarking Studies

We conduct economic benchmarking analyses to identify comparable uncontrolled transactions or companies, applying the most appropriate transfer pricing method for each category of transaction, whether it involves the sale of goods, provision of services, royalty payments, or intra-group financing arrangements.

Local File and Master File Documentation

We prepare the local file documentation required under Indian transfer pricing rules, capturing the functional, asset, and risk profile of the entity along with the economic analysis supporting the pricing adopted, and assist larger groups in preparing or collating the master file that describes the global business and value chain of the multinational enterprise.

Country-by-Country Reporting (CbCR) Compliance

For groups that meet the applicable consolidated revenue threshold, we assist with the preparation and filing of country-by-country reports, as well as the intimation and notification filings required from Indian constituent entities of foreign multinational groups.

Assessment and Dispute Support

When a transfer pricing assessment is initiated, we prepare submissions, respond to queries from the transfer pricing officer, and represent the taxpayer through the assessment, and where necessary through dispute resolution mechanisms such as the Dispute Resolution Panel or appellate proceedings, drawing on the underlying benchmarking and documentation to support the position taken.

Who Needs This

• Indian subsidiaries of foreign multinational groups engaging in cross-border intercompany transactions
• Indian groups with domestic related-party transactions that exceed the specified thresholds
• Businesses entering into new intercompany arrangements such as management fees or cost allocations
• Companies facing an ongoing or anticipated transfer pricing audit

Our Approach

We build transfer pricing documentation that is grounded in a genuine understanding of how the business actually functions, rather than a generic template exercise, so that the pricing rationale is defensible on its merits during an audit. Our benchmarking work is refreshed to reflect current market data and evolving business circumstances, keeping documentation contemporaneous and reducing the risk of adjustments later.

Get in Touch

To discuss how we can support you with transfer pricing services, write to us at info@agarwalurs.com.