International Transactions Audit Defense Compliance

Transfer Pricing

Your business grows globally — we keep your Transfer Pricing legally aligned. A strong framework to reduce litigation risk and ensure global tax efficiency.

Service Summary What's Included Deliverables
Global Business
Documents
Analysis

Service Summary OECD Aligned

Transfer Pricing Advisory focuses on pricing transactions between related parties / associated enterprises (AEs) across borders. Since multinational groups operate in multiple tax jurisdictions, every intercompany transaction must comply with the Arm’s Length Principle (ALP) as per OECD Guidelines & Indian Income-tax Act, 1961.

We ensure arm’s-length pricing for international and specified domestic transactions with complete documentation, reducing litigation risk, preventing double taxation, and protecting margins.

Suggestive Guidance: Safe Harbour (SHR)

If your international transactions fall under SHR eligibility (e.g., turnover/transaction value ≤ ₹ 300 crore for 2025-26), you may opt for the SHR route to get predefined margins and certainty. This significantly reduces the likelihood of TP adjustments or litigation.

Corporate Buildings
Risk Assessment Global Strategy

What's Included End-to-End

Comprehensive coverage from study reports to audit representation.

TP Study Report & Benchmarking

Detailed analysis and benchmarking matrix to justify pricing policies.

Mandatory Filings (Form 3CEB)

Timely filing of Form 3CEB, Master File (Form 3CEAA/AB), and CbCR.

Safe Harbour Advisory

Strategic advice on leveraging SHR thresholds (up to ₹300 Cr) for IT/ITES.

Litigation Support & Defence (Add-on)

Representation in TP audits, before TPO/CIT(A)/ITAT, and drafting rebuttals.

Inter-company Agreements

Reviewing and drafting agreements to ensure they match the TP study.

Deliverables Tangible Value

Documents and reports you will receive.

Comprehensive TP Documentation
Benchmarking matrix
TP Risk Assessment report
Form 3CEB Filing Acknowledgement
Annual TP Policy & Pricing Model
Independent auditor-certified report

Cross-border transactions?

Keep your business clean, compliant, and stress-free.

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