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

Union Budget 2024

Decoding the provisions of the Union Budget 2024 and their impact on your business

Tax brochure

Transfer pricing Services

The “Guidance on the transfer pricing implications of the COVID-19 pandemic” issued by the Organisation for Economic Co-operation and Development (OECD) in December 2020, represents the consensus view of the 137 members of the Inclusive Framework on BEPS regarding the application of the arm’s length principle and the OECD Transfer Pricing Guidelines to issues that may arise or be exacerbated in the context of the COVID-19 pandemic. The guidance is helpful both for taxpayers in reporting the financial periods affected by the pandemic and for tax administrations in evaluating the implementation of taxpayers’ transfer pricing policies. The Guidance provides clarifying comment on, and illustrations of, the practical application of the arm’s length principle in four priority issues, identified in consultation with Business at the OECD: (i) comparability analysis; (ii) losses and the allocation of COVID-19 specific costs; (iii) government assistance programmes; and (iv) advance pricing agreements.

Click to know more