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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 embrace technical expertise and industry knowledge to support you worldwide through our international network of member firms. We will design and implement sustainable and compliant transfer pricing models with you, which create unique opportunities to drive business value and foster growth.
We can turn compliance into effective cooperation between tax authorities and businesses. This requires having deep knowledge of the value chain and control over the narrative to avoid tax disputes from the outset as much as possible. However, when disputes arise, our above-market involvement of senior resources ensures leveraging best practices helping you manoeuvre around these obstacles locally or internationally through Advance Pricing Agreements and Mutual Agreement Procedures.
We will help you understand the complexity of transfer pricing and prepare for scrutiny from tax and financial auditors. This is embedded into a risk-oriented and pragmatic approach to ensure cost-efficient solutions to 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.
Identify opportunities to optimise tax efficiency during business expansion, restructuring or cross-border growth by developing effective transfer pricing strategies.
Prepare and validate country-specific documentation in line with local regulations, supported by functional and economic analysis to ensure full compliance.
Operationalise transfer pricing policies through consistent processes, benchmarking, financial transactions support and value chain optimisation.
Mitigate disputes and respond to enquiries through sophisticated economic analysis, dispute management strategies, Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs).
At Grant Thornton Bharat, we provide end-to-end transfer pricing support across compliance, advisory, operational execution and dispute resolution. Our approach blends technical depth, commercial understanding and practical experience to help you meet regulatory expectations while optimising your global value chain.
We manage all statutory transfer pricing requirements for international and specified domestic transactions, including preparing functional and comparability analyses, conducting industry and business reviews, and issuing the Accountant’s Report in Form 3CEB. Our teams also support multi-jurisdictional documentation studies, as well as Master File and Country-by-Country reporting — from preparation and filing to handling 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.
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 provide extensive support on Related Party Transaction (RPT) governance under the Companies Act and SEBI regulations — identifying related parties, assessing arm’s length conditions, evaluating approval requirements and reviewing compliance on a periodic basis. Beyond this, we assist with profit attribution studies, global TP policy documents, supply chain restructuring, inter-company agreements and benchmarking of financial transactions, enabling operational alignment and regulatory readiness.
We help clients proactively reduce the risk of disputes and manage them effectively when they arise. 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. 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 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.
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 your operational and compliance needs
From conducting a comprehensive review of RPTs to documentation and related approval processes, we offer bespoke solutions to help you navigate RPT governance.
