Chartered Accountants

Transfer Pricing and International Taxation

We offer specialized advisory and compliance services in the domain of transfer pricing and international taxation, assisting multinational enterprises (MNEs), joint ventures and Indian entities with cross-border operations. Our objective is to help clients align their global tax positions with both Indian and international regulatory expectations.

Our transfer pricing services include preparation of Local File and Master File under Indian TP rules, country-by-country reporting (CbCR) and maintenance of Form 3CEB. We conduct functional, asset and risk (FAR) analysis to evaluate intercompany transactions and benchmark them using Indian and international financial databases. We help clients choose the Most Appropriate Method (MAM), such as CUP, TNMM or Resale Price Method, to justify pricing of international and specified domestic transactions.

We assist clients in preparing transfer pricing documentation that meets the requirements of Indian Income Tax Rules and OECD Guidelines. During scrutiny or transfer pricing audits, we provide end-to-end support including data validation, risk assessment, drafting replies and representation before tax authorities and appellate bodies.

Our international tax services include structuring of inbound and outbound investments, analyzing the applicability of Permanent Establishment (PE) under tax treaties, evaluating foreign tax credits and optimizing cross-border remittances under Section 195. We help clients manage the implications of Base Erosion and Profit Shifting (BEPS), General Anti-Avoidance Rules (GAAR) and equalization levy.

We also offer strategic advice on tax implications under Double Taxation Avoidance Agreements (DTAA) for services, royalties, interest payments, technical fees and dividends. Our team regularly advises on transfer pricing impact during mergers, acquisitions and restructuring of international business models.

With global tax authorities increasing coordination and data sharing, businesses require robust compliance frameworks. We help clients proactively manage global tax risks while maintaining commercial efficiency. Our goal is to ensure transparency, accuracy and alignment with international best practices while minimizing the risk of double taxation and disputes.