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Global transfer pricing is all about understanding your business and the value drivers of your industry in an ever-changing environment.
We combine technical expertise and industry knowledge to support you worldwide through our international network of member firms. We work with you to design and implement sustainable and compliant transfer pricing models, helping create opportunities to drive business value and foster growth. We turn compliance into effective cooperation between tax authorities and businesses. This requires a deep understanding of the value chain and control over the narrative to help avoid tax disputes from the outset.
A strong transfer pricing position also requires a clear economic narrative: one that connects contractual terms with actual conduct, value creation, risk control and commercially rational outcomes. When disputes arise, our senior-led approach ensures that best practices are leveraged, helping you navigate challenges locally or internationally through Advance Pricing Agreements and Mutual Agreement Procedures.
We help you understand the complexity of transfer pricing and prepare for scrutiny from tax and financial auditors. This is embedded in a risk-oriented and pragmatic approach designed to deliver cost-efficient solutions that meet your priorities.
Transfer pricing requires a clear understanding of your value chain, industry drivers and business objectives. We work closely with you to design and implement transfer pricing models that align with your operations, minimise tax risk, support growth and meet regulatory expectations in every jurisdiction. We assess the economic reality of intercompany arrangements, helping clients demonstrate why a related-party transaction makes commercial sense and how its pricing aligns with value creation, given market conditions.
At Grant Thornton Bharat, we provide end-to-end transfer pricing support across planning, implementation, documentation, defence and dispute avoidance. Our approach blends technical depth, commercial understanding and practical experience to help you meet regulatory expectations while optimising your global value chain.
Our advisory services help organisations strengthen their transfer pricing frameworks, whether they are designing a new operating model, restructuring for efficiency or validating existing policies. We assist with developing pricing arrangements, performing health checks, undertaking due diligence for acquisitions and reviewing deemed international transactions. We also assist with profit attribution studies, global transfer pricing policy documents and supply-chain restructuring.
For complex or high-value transactions, we bring an economic lens to assess value drivers, pricing logic, allocation keys and financial assumptions, helping clients design policies that are commercially coherent as well as technically compliant.
We help organisations translate approved transfer pricing policies into practical, day-to-day operating frameworks. This includes aligning intercompany agreements with the transfer pricing policy and the parties' actual functions, risks and conduct, while ensuring pricing mechanisms are consistently applied across controlled transactions.
Our support extends to defining allocation keys, mark-ups, royalty rates, target margins and adjustment mechanisms, coordinating transfer pricing requirements with invoicing, accounting and financial reporting processes, and monitoring outcomes against the policy. We also assist with governance, including Related Party Transaction (RPT) compliance under the Companies Act and SEBI regulations, periodic reviews, supporting documentation and updates required as business models, transaction flows or regulatory requirements evolve.
We manage statutory transfer pricing requirements for international and specified domestic transactions, including preparing functional and comparability analyses, conducting industry and business reviews, and supporting transfer pricing documentation and compliance requirements.
Our teams also support multi-jurisdictional documentation studies, as well as Master File and Country-by-Country Reporting, from preparation and filing to managing complexities such as ARE structures, non-exchange jurisdictions and communication with tax authorities. With our support, businesses can maintain consistent, defensible and timely compliance across jurisdictions.
We help clients manage transfer pricing disputes effectively when they arise. In ongoing disputes, we draft submissions and appeals, represent clients before TPOs, CIT(A), DRPs and Appellate Tribunals, and advise on litigation strategy, including coordination with external counsel for High Court and Supreme Court matters.
Where disputes turn on economic substance, such as in benefit testing, cost contribution, intangibles, business restructuring or complex financing arrangements, we help develop the economic evidence and analytical narrative required to support the taxpayer’s position.
We help clients proactively reduce the risk of transfer pricing disputes. Our end-to-end APA support includes transaction selection, strategy design, document preparation, pre-filing consultations, application filing, responding to queries, and assisting with negotiations and compliance audits.
For safe harbour, we review eligible transactions, prepare applications and represent clients before authorities.Where cross-border adjustments result in double taxation, we support clients through the Mutual Agreement Procedure (MAP) process. Our services include analysing facts and transfer pricing adjustments, reviewing documentation, preparing representations for competent authorities, and facilitating negotiations between jurisdictions until closure, with a focus on fair, timely and practical outcomes.
Related-party transactions increasingly need to be supported not only through legal documentation and benchmarking, but also by demonstrating their underlying economic substance. We help clients articulate the commercial rationale, value contribution, risk allocation and market context underpinning intercompany arrangements, ensuring transfer pricing outcomes reflect how the business actually operates.
Our economic support combines transfer pricing expertise, sector knowledge, data analytics and economic methods to strengthen positions relating to royalties, intra-group services, financial transactions, profit splits, business restructurings and intangibles. By combining economic reasoning with practical documentation and dispute readiness, we help clients build transfer pricing positions that are robust, defensible and commercially aligned.
For a consolidated view of transfer pricing rules and regulations across major jurisdictions, explore our Global transfer pricing guide. It brings together essential information on transfer pricing frameworks, documentation requirements and country-by-country reporting obligations, helping you easily access the regulatory insights you need for every country in which you operate.
We bring practical, agile expertise to help you navigate the complex ways transfer pricing affects your business, from strategy and governance to implementation and audit readiness.
You benefit from direct access to senior specialists and partners who are deeply engaged, hands-on and genuinely passionate about delivering effective transfer pricing solutions.
We combine global perspective with local insight, building cohesive, sustainable transfer pricing models that work across jurisdictions while supporting operational and compliance needs.
While many environmental, social, and governance (ESG) frameworks and reporting standards remain technically voluntary, ESG considerations are becoming increasingly relevant to how multinational enterprises operate, report, and manage cross-border compliance.
The tax and regulatory environment continues to evolve rapidly, with significant developments on both judicial and legislative fronts. To keep you ahead of these developments, we present the September 2026 edition of the Grant Thornton Bharat Monthly Tax Bulletin. This edition provides a concise summary of key developments in direct taxes, FEMA, transfer pricing and indirect taxes for August 2026.
Corporate guarantees, traditionally used as instruments of group financing and treasury support, have emerged as a recurring area of tax controversy, evolving from predominantly a ‘consideration’ centric debate under the erstwhile service-tax regime to the broader questions of supply, valuation and point of tax under GST.
The August 2026 edition of the Grant Thornton Bharat Monthly Tax Bulletin provides a concise summary of key developments in direct taxes, FEMA, transfer pricing, and indirect taxes for July 2026.
From conducting a comprehensive review of RPTs to documentation and related approval processes, we offer bespoke solutions to help you navigate RPT governance.
