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Overview of Transfer Pricing
in India

Overview of Transfer Pricing in India

Transfer pricing is becoming a top risk management concern for multinational corporations due to the rise in intercompany transactions.


There is a considerable amount of litigation regarding transfer pricing in India. By offering companies useful transfer pricing services & solutions that are in line with their worldwide business and aims and that also offer dispute management, we hope to help businesses.


Transfer Pricing in India is one of the key ideas in the worldwide tax framework, which is now relevant in every nation as a result of globalisation.

What is Transfer Pricing?

The prices at which one business transfers tangible commodities, intangible property, or services to its affiliated businesses are referred to as transfer pricing.


Rising transaction volumes and a wide range of everyday operating transactions, globalisation and the international tax environment have presented multinational businesses with a distinctive set of issues. International Transfer Pricing in India has become a crucial issue for many international businesses as a result of the constantly changing global regulatory environment and rising pressure from national legal organisations.

Transfer Pricing in India:

Transfer Pricing in India refers to the exchange rates offered by one multinational group member to another member outside the nation for the exchange of tangible and intangible goods and services. Businesses should use a systematic strategy for Risk Management and controls together with Compliance responsibilities such as documentation, records, process, etc., as transfer pricing in India is a constant activity.


Our Transfer Pricing Consultants and tax experts having experience working with multinational clients can be your counsel for complex areas of International Transfer Pricing Services. With the help of our transfer pricing services, you may achieve your international business objectives by developing a clear transfer pricing strategy that complies with regulatory requirements.


Through ongoing financial analysis and strategic interventions, our transfer pricing consultants can provide crucial guidance on the transfer pricing model that fits your value chain. In order to position your Transfer Pricing model to comply with regulatory requirements, we make sure to document all intercompany transactions. Our Tax Advisors and Transfer Pricing Consultants can help you navigate challenging Transfer Pricing problems and reduce the risks of non-compliance. 

We offer a variety of services, from managing big international tasks like Country by Country reporting to providing APA services. We are a dynamic organisation that supports clients in making corporate decisions at various stages of inter-company transactions by offering customised solutions, such as planning, policy creation, implementation, strong documentation, and compliance, along with supporting 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 liaisoning 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

How can YKG Corp. help?

YKG Corp, a highly reputed consulting firm, with pan India presence has a wide range of experienced professionals who have been assisting a significant number of clients in complying with the transfer pricing documentation cum compliance requirements.


+91 9910220566 



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