Transfer Pricing

Advising on transfer pricing policies, documentation and regulatory compliance for international transactions

International Taxation

Transfer Pricing

Overview

We advise businesses on transfer pricing compliance and documentation for international and specified domestic transactions. Our services help organisations demonstrate that related party transactions are undertaken at arm's length in accordance with the Income-tax Act, 2025 and internationally accepted transfer pricing principles.

Scope of Services

Our Transfer Pricing services include:

  • Transfer pricing planning and advisory for international and specified domestic transactions.
  • Preparation and review of transfer pricing documentation and benchmarking studies.
  • Determination of the Most Appropriate Method (MAM) and arm's length pricing.
  • Assistance in maintaining prescribed transfer pricing documentation.
  • Review of inter-company agreements and pricing policies.
  • Advisory on Advance Pricing Agreements (APA) and Safe Harbour provisions.
  • Representation during transfer pricing audits, assessments and dispute resolution proceedings.
  • Advisory on transfer pricing implications of business restructurings and cross-border transactions.

Our Approach

We analyse the commercial substance of related party transactions, industry practices and applicable transfer pricing provisions to develop practical and defensible pricing policies. Our approach balances regulatory compliance with commercial objectives while mitigating transfer pricing risks.

Key Benefits

  • Compliance with transfer pricing regulations under the Income-tax Act, 2025.
  • Robust documentation to support arm's length pricing.
  • Reduced risk of transfer pricing adjustments and penalties.
  • Well-reasoned benchmarking and pricing methodologies.
  • Practical solutions aligned with business operations.
  • Professional support during audits, assessments and dispute resolution.