Transfer Pricing Advisory & Documentation

Ensure your international and domestic related-party transactions comply with Indian TP regulations. Chintan Agrawal & Co. delivers expert guidance, accurate documentation, and audit defense.

From Form 3CEB to APA, we simplify complex pricing compliance so you focus on global growth.

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Why Transfer Pricing Compliance Matters

In a globalised economy, intercompany transactions must reflect fair market value. Failure to comply with Indian TP laws can lead to heavy penalties and litigation.

  • Avoid Adjustments: Prevent tax additions due to underreported profits in India.
  • International Credibility: Demonstrate compliance to investors, regulators, and partners.
  • Peace of Mind: Navigate assessments and audits with solid documentation and expert advice.
GST registration process

Types of Transfer Pricing Support

TP Study & Documentation

Comprehensive analysis and Form 3CEB preparation

Benchmarking Report

Global comparables & economic analysis

TP Audit Defense

Submissions & representation during scrutiny

Policy Planning

Intercompany pricing structuring for future transactions

Master File & CbCR

Support for large MNEs under BEPS requirements

Advance Pricing Agreements (APA)

Strategic assistance in applying for APAs with CBDT

Process for Transfer Pricing

Our step-by-step methodology ensures your related-party transactions meet global transfer pricing standards and Indian tax compliance requirements.

  • ✔️

    Identify all international and specified domestic transactions with related parties, including tangible goods, services, loans, IP, or cost-sharing arrangements.

  • ✔️

    Conduct a detailed Functional, Asset, and Risk (FAR) analysis to understand the economic substance of each transaction and allocate risk properly.

  • ✔️

    Determine the most appropriate transfer pricing method (CUP, TNMM, Cost Plus, etc.) as per Rule 10B of Indian Income Tax Rules.

  • ✔️

    Perform benchmarking using global databases (like Prowess or Capitaline) to find comparable uncontrolled transactions for arm’s length validation.

  • ✔️

    Prepare mandatory documentation including Transfer Pricing Study Report and Form 3CEB certified by a Chartered Accountant.

  • ✔️

    Support during assessments, audits, and tax litigation, with strong documentation and technical defense for each transaction.

GST registration process

Benefits of Transfer Pricing Compliance

Information & Documents Required

Group Entity List

Details of all associated enterprises involved in international/domestic transactions.

Agreements & Invoices

Copies of intercompany contracts and corresponding transactional documents.

Pricing Methodology

Explanation of transfer pricing method adopted—CUP, TNMM, CPM, etc.

Financial Statements

Standalone and consolidated financials of the Indian and foreign entities.

Functional Analysis

Details of functions performed, assets used, and risks assumed by each entity.

Industry & Economic Data

Supporting market data, segmental margins, and macroeconomic indicators.

Frequently Asked Questions

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