Transfer Pricing Documentation

Transfer pricing is the discipline of determining appropriate prices for inter-company transactions—say, when one Indian group company sells goods to a Singapore affiliate or provides management services to a US subsidiary. Tax authorities worldwide, including the Indian Revenue, scrutinize these prices to prevent profit shifting to low-tax jurisdictions. If your pricing cannot be justified as arm's length—i.e., as if unrelated parties struck the same deal—you face reassessment, penalties, and double taxation.

We help you win this chess game by building a water-tight transfer pricing position. We benchmark your inter-company transactions against comparable independent transactions, document your functional analysis (what functions each party performs, what risks they bear), and align your pricing with the OECD Transfer Pricing Guidelines that Indian courts now reference. Our documentation is designed to withstand income tax authority scrutiny and, if needed, dispute resolution proceedings.

We also advise on the tax treaty implications of your transfer pricing, helping you reduce double taxation through Mutual Agreement Procedures (MAPs) with foreign tax authorities. For businesses with complex supply chains or intellectual property licensing, transfer pricing is not optional—it is mission-critical to your tax compliance.