2.03 · Tax & Compliance
Transfer Pricing
Setting the arm's length price (ALP) for international transactions, with documentation built to withstand scrutiny.
Service docket
- Register no.
- 2.03 · 3 of 4 in desk
- Scope
- 5 items
- Deliverables
- 4
Named on this page
- Form 3CEB
- Master File
- CbCR
- APA
01 · Overview
Overview
Cross-border transactions between related parties are a leading target for tax authorities. We carry out detailed functional analyses (functions, assets and risks) to support your pricing model.
We then prepare the annual documentation and certification, and represent you if the pricing is questioned.
02 · Scope
What we do
Arm's length pricing for related-party transactions, documented to withstand scrutiny.
- Line 01FAR (functions, assets, risks) analysis
- Line 02Benchmarking studies using comparable company data
- Line 03Accountant's report on international transactions (Form 3CEB for FY 2025-26 and earlier)
- Line 04Master File, Local File and Country-by-Country Reporting (CbCR)
- Line 05Dispute resolution (DRP) and advance pricing agreements (APA)
03 · Deliverables
Deliverables
What you receive from the engagement.
RET-01Tax & Compliance
Transfer pricing study with the benchmarking set
RET-02Tax & Compliance
Certified accountant's report filed on time
RET-03Tax & Compliance
Master File and CbCR filings where thresholds apply
RET-04Tax & Compliance
Submissions and representation in TP assessments
04 · Companies
Who it is for
- 01
Captive development and service centres of foreign groups
- 02
Indian distributors and manufacturers buying from group companies
- 03
Groups with intra-group loans, guarantees, royalties or management fees
05 · Compliance
Related compliance
Guides and calendars
Forms, registrations and systems named on this page
- Form 3CEB
- Master File
- CbCR
- APA
06 · More in this desk
Related services
- Managed ServicesAudit & AssuranceStatutory and regulatory audit for Indian companies and foreign subsidiaries.
- Market EntryFEMA & RBI ComplianceForeign investment reporting and capital-flow structuring with your Authorised Dealer bank.
- Tax & ComplianceUS Tax Advisory (IRS)A back-office tax department for CPAs and US entities, federal and state.
- Managed ServicesVirtual CFOFinancial leadership without a full-time executive.
Need a hand?
Email info
Discuss Transfer Pricing with us
Tell us about your entity and what you need. We reply with a scope and fee proposal under a formal engagement letter.