Our Transfer Pricing team provides a range of services from provision of APA services to handling large global assignments including Country by Country reporting. We are a dynamic organisation assisting clients in corporate decision-making at different stages of inter-company transactions by providing tailored solutions i.e. planning, policy-making, implementation, robust documentation and compliance along assisting clients before the revenue and appellate authorities.


  • Local transfer pricing compliance documentation for international transactions and specified domestic transactions including:
    • Functional analysis
    • Comparability analysis
    • Industry and business overview
  • Assistance in obtaining of an Accountant’s Report in Form 3CEB
  • Master File and country-by-country (CbC) reporting
    • Assistance in preparation of Master File
    • Assistance in preparation of CbC Report where:
      • The ultimate parent company is in India
      • The Indian entity is designated as the Alternative Reporting Entity (ARE)
      • Indian entity does not have an agreement for exchange of CbC Report with country of foreign parent
      • Despite having an exchange agreement, country of foreign parent (or ARE) fails to share CbC Report
    • Assistance in communicating and liasoning with the relevant prescribed authorities whenever required


  • Assistance in setting up business/operational model
  • Restructuring of existing business model to build tax/commercial efficiencies
  • Due diligence report (DDR) assistance from transfer pricing perspective in order to ensure that the business model and pricing arrangements of target acquisition are defensible
  • Assistance in corporate governance under Companies Act, 2013 and SEBI regulations
    • Identification of related parties
    • Analysing the identified RPT as to:
      • Whether the transactions are in the ordinary course of business; and
      • Whether the transactions are proposed to be undertaken on arm’s length basis
    • Analysing and evaluating various approvals that may be required (i.e. Audit Committee, Board of Directors, shareholders etc.) for each of the RPT under the Companies Act 2013 and SEBI regulations
    • Review-related party compliances under the Companies Act on a quarterly/half-yearly/annual basis
    • Present our analysis at board meetings to assure Directors that compliances are in order
  • Review of deemed international transactions
  • Assistance in preparing profit attribution studies
  • Assistance in preparing global transfer pricing policy document
  • Supply chain restructuring
  • Structuring management fee payments, royalty payments, inter-company financing arrangements

Dispute Avoidance/Resolution

  •  Assistance in representation before:
    • Transfer Pricing Services Officer
    • Commissioner of Income Tax (Appeals)
    • Dispute resolution panel
    • Appellate tribunals
  • Drafting of submissions, appeals and letters to the revenue/appellate authorities
  • Tax briefings and providing external support to external counsels for representation before High Courts and Supreme Court
  • Assistance in Advance Pricing Agreements (APA) proceedings
  • Assistance with mutual agreement procedures (MAP)
  • Assistance in relation to Safe Harbour application

For any queries, write us at contact@in.gt.com