Transfer Pricing Services in India

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Global multinational enterprises today operate in an environment of increasing complexity. With a surge in inter-company transactions—both within India and across borders—and continuous changes in transfer pricing regulations, each country seeks to maximize its tax revenues. This, combined with stricter enforcement by tax authorities, has made Transfer Pricing and the determination of the Arm’s Length Price (ALP) one of the most critical risk management concerns for businesses.

Transfer Pricing Services in India
KM Gatecha and Co LLP Chartered Accountants
transfer pricing services

Phone No - +91 80000 57972

Mail us at - services@kmgcollp.com

Visit – www.kmgcollp.com

    In India, the active implementation of transfer pricing laws and growing adjustments on intricate issues have highlighted the fact that transfer pricing disputes are costly, time-consuming, and often result in double taxation and significant uncertainty. Moreover, with the introduction of the Base Erosion and Profit Shifting (BEPS) framework, transfer pricing has become an even greater area of scrutiny for both India and other tax jurisdictions worldwide.

    Our Transfer Pricing team offers a comprehensive suite of services in India, ranging from Advance Pricing Agreements (APA) to managing large-scale international assignments, including Country-by-Country (CbC) Reporting. We assist clients in strategic decision-making throughout the entire lifecycle of inter-company transactions, offering customized solutions for planning, policy formulation, implementation, compliance, and documentation. Additionally, we represent clients before tax and appellate authorities to ensure smooth resolution of disputes.

    Transfer Pricing Services in India

    Our Transfer Pricing Services in Ahmedabad, Gujarat include the following:

    Compliance Services

    • Preparation of detailed transfer pricing documentation for international and specified domestic transactions, including:

      • Functional Analysis

      • Asset Analysis

      • Risk and Industry Overview

    • Preparation and filing of the Accountant’s Report (Form 3CEB)

    • Master File and Country-by-Country (CbC) Reporting support

    • Assistance in preparing Master File and CbC Report where:

      • The ultimate parent entity is based in India

      • The Indian entity is designated as the Alternative Reporting Entity (ARE)

      • The Indian subsidiary lacks an exchange agreement with the parent’s jurisdiction

      • An exchange agreement exists, but the foreign parent (or ARE) fails to share the CbC Report

    • Coordination and communication with the relevant tax authorities

    Advisory Services

    • Support in business setup and operational model structuring

    • Restructuring existing models to enhance tax and commercial efficiencies

    • Due Diligence Report (DDR) assistance from a transfer pricing perspective to evaluate the defensibility of pricing arrangements during acquisitions

    • Review and analysis of deemed international transactions

    • Preparation of profit attribution studies

    • Development of global transfer pricing policy documents

    • Supply chain restructuring for improved tax outcomes

    • Structuring of management fee, royalty payments, and inter-company financing arrangements

    Our goal is to help organizations achieve compliance, minimize transfer pricing risks, and establish robust, defensible pricing structures aligned with global standards and Indian regulations.

    Transfer Pricing Services in India

    Dispute Avoidance and Resolution

    Our Transfer Pricing team provides end-to-end support in effectively managing disputes and minimizing litigation risks. We help clients navigate complex tax controversies through proactive dispute avoidance measures and strong representation before relevant authorities.

    Our services in Dispute Avoidance and Resolution include:

    • Representation and assistance before:

      • Transfer Pricing Officer (TPO)

      • Commissioner of Income Tax (Appeals)

      • Dispute Resolution Panel (DRP)

      • Income Tax Appellate Tribunal (ITAT)

    • Drafting and preparation of submissions, appeals, and responses to revenue and appellate authorities

    • Providing tax briefings and external support to legal counsels for representation before the High Courts and Supreme Court

    • Assistance in Advance Pricing Agreement (APA) proceedings for achieving certainty on transfer pricing positions

    • Support in Mutual Agreement Procedures (MAP) to resolve international double taxation issues through competent authority negotiations

    • Guidance and assistance in filing Safe Harbour applications to ensure compliance and reduce transfer pricing litigation risks

    Transfer Pricing Services in India

    Our approach focuses on strategic representation, practical solutions, and dispute prevention to help organizations achieve tax certainty and maintain compliance with evolving transfer pricing regulations.

    FAQs

     Transfer Pricing refers to the pricing of goods, services, and intangibles between related entities in different tax jurisdictions. It ensures that transactions are conducted at an Arm’s Length Price (ALP)—the price that unrelated parties would charge under similar conditions—helping maintain tax fairness and avoid profit shifting.

     Any company that enters into international or specified domestic transactions with associated enterprises is required to comply with Indian Transfer Pricing laws under Sections 92 to 92F of the Income Tax Act, 1961.

     Businesses must maintain detailed documentation, including Form 3CEB, Master File, and Country-by-Country (CbC) reports, along with supporting analyses like functional, risk, and economic studies.

     An APA is an arrangement between a taxpayer and tax authority determining the ALP for future transactions. It helps reduce uncertainty, prevent disputes, and ensure tax compliance.

    MAP provides a mechanism to resolve double taxation disputes between countries through mutual consultation between competent authorities, ensuring fairness and relief for taxpayers.

     Safe Harbour Rules specify acceptable margins or pricing parameters for certain transactions. Taxpayers following these rules are generally protected from detailed scrutiny, reducing compliance risk.

     BEPS (Base Erosion and Profit Shifting) aims to prevent tax avoidance by shifting profits to low-tax jurisdictions. It introduced stricter disclosure requirements like CbC reporting and greater scrutiny of intra-group transactions.

     Key risks include non-compliance with documentation, incorrect ALP determination, inadequate functional analysis, and exposure to double taxation or penalties during audits.

    A professional consultant provides end-to-end support—from planning and policy formulation to documentation, compliance, dispute resolution, and regulatory representation—ensuring tax efficiency and legal protection.

     Non-compliance can lead to tax adjustments, penalties, interest, and double taxation, along with increased scrutiny from tax authorities. Proper documentation and expert guidance are essential to mitigate such risks.