When does transfer pricing apply to a purely Indian group?

Assurance, Tax & Advisory

Transfer Pricing

Benchmarking, documentation, Form 3CEB certification and dispute support for related-party transactions across borders and within groups.

Overview

Transfer pricing is the tax discipline most often decided by paperwork prepared long before the question is asked. The economic analysis has to be contemporaneous, the comparables defensible, and the intercompany agreements consistent with what the parties actually do. Where those three line up, the position holds. Where they do not, the adjustment tends to follow.

What this covers

How we help

Benchmarking study

Comparability analysis and selection of the most appropriate method for each transaction.

Documentation

Local file, master file and contemporaneous documentation maintained to the prescribed standard.

Form 3CEB certification

Accountant's report on international and specified domestic transactions.

Intercompany agreements

Reviewing agreements so the legal terms match the conduct and the pricing.

Assessment and appellate support

Representation through transfer pricing scrutiny, DRP and appellate proceedings.

Country-by-country reporting

Notification and reporting obligations for groups above the prescribed threshold.

Common questions

Transfer Pricing — questions we are asked

Specified domestic transactions between related parties can fall within the transfer pricing provisions where prescribed conditions and thresholds are met. Groups often assume the rules are only cross-border and discover otherwise during an assessment, so the position should be checked for the specific facts.

Talk to us about transfer pricing

A short conversation is usually enough to establish whether this is the right route, and what it would involve.

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