Transfer pricing (Domestic & International

SP Kapoor > Transfer pricing (Domestic & International)



International Transfer Pricing

Transfer pricing regulations in India have emerged as one of the most important and critical areas of tax policy and administration, tax planning and tax controversy for global corporate setting up business establishments in India. We assist companies in decision making at various stages of inter-company transactions – planning, policy making, strategy, implementation, compliance and justifications.

Service Offerings In Transfer Pricing:

Our Transfer Pricing professionals provide comprehensive solutions tailored to your business objectives after understanding the exact nature and the extent of the international transactions undertaken by the Company. We have a specialized Transfer Pricing team that is competent to assist you in the following areas of Transfer Pricing

Transfer Pricing Documentation Services:

Preparation of comprehensive Transfer Pricing study, which includes:

  • A fact-finding exercise, where an analysis is conducted of the functions performed and risks assumed by each entity.
  • Evaluation of prescribed Transfer Pricing Methods and selection of the most appropriate Transfer Pricing Method and identification of the tested party or parties.
  • Undertaking a search for comparable companies /comparable transactions using domestic/ global databases and conducting economic and financial analyses on the selected comparables.
  • Preparation of a comprehensive Transfer Pricing Documentation incorporating the above steps.
  • Arranging issuance of the Accountant’s Report in Form 3CEB as required under Indian Income-tax Act, 1961.

Transfer Pricing Strategy Services:

  • Undertaking Transfer Pricing Planning studies for determination of the appropriate Transfer Pricing margin for newly set up companies/new business lines/business units/new transactions.
  • Transfer Pricing diagnostic reviews.
  • Review of Transfer Pricing policy for assessing possible transfer pricing risks.
  • Review of the overall supply chain of the organization and recommending a Tax Efficient/ Transfer Pricing compliant supply chain structure.
  • Reviewing inter-company agreements from a transfer pricing perspective.
  • Structuring cost sharing arrangements for domestic and international inter-company transactions.
  • Valuation of intangible assets from a Transfer Pricing perspective.


Domestic Transfer Pricing

Domestic Transfer Pricing is applicable on domestic companies where the specified transactions between the associated enterprises exceed Rs. 20 crores. We provide all the services related to domestic transfer pricing.