Transfer Pricing, defensible.
Every cross-border related-party transaction is one TPO notice away from a multi-crore adjustment. We build benchmarking studies and TP documentation that hold up under scrutiny, and represent you when they don't.
Does my Indian subsidiary need transfer pricing documentation?
Yes: any transaction with a foreign parent, sister concern, or associated enterprise (sales, services, royalty, loan, cost-share, IP) requires Form 3CEB, a benchmarking study, and contemporaneous documentation. There is no de-minimis threshold. We handle entire compliance and defence cycle.
Benchmarked. Documented. Defended.
We treat transfer pricing as a litigation discipline, not a compliance checkbox. Every margin we file is supported by a comparable set we are willing to defend before TPO, DRP, and ITAT.
Map functions performed, assets employed, and risks borne by each associated enterprise. This determines characterisation and right TP method.
Database search (Prowess, Capitaline, RoyaltyStat) to identify comparables. Quantitative and qualitative screening to arrive at arm's length range.
Contemporaneous documentation per Rule 10D: industry analysis, entity overview, controlled transactions, FAR, economic analysis. Maintained for 8 years.
Independent CA report covering every international transaction and SDT. Filed by 31 October each year. We sign and defend what we file.
Form 3CEAA (Master File) and 3CEAD (CbCR) for qualifying multinational groups. Coordination with global parent for consistent positioning.
Where audit exposure is high, we file Advance Pricing Agreements or Safe Harbour applications. When TPO has already issued a notice, we lead defence to DRP and ITAT.
Key checkpoints. Miss none.
Documents we'll ask for.
A clean document set cuts our turnaround in half. Send what you have. We'll request anything outstanding in a single consolidated checklist.
One TP notice can cost crores.
Get a 30-minute risk review of your existing documentation. We will tell you exactly where exposure sits, and what to fix before your next 3CEB filing.