TP Documentation
Preparation of mandatory Local File, Master File, and Country-by-Country Report documentation meeting prescribed timelines, formats, and content requirements under Indian regulations.
Core Tax Services
Transfer Pricing
Practice01/06
TP Documentation.
Note01Refer — Scope
Form 3CEB, Local File, Form 3CEAA (Master File), and Form 3CEAD (CbCR) preparation.
Index06 Practices
Transfer Pricing Services We Provide
India's transfer pricing regulations require multinational groups to document and justify related-party transaction pricing. Our services address each compliance requirement methodically.
Policy Development
Assistance in developing transfer pricing policies aligned with your functional profile, business model, and the arm's length standard required by Indian tax law.
Benchmarking Analysis
Functional analysis and comparability studies using reliable databases to identify arm's length ranges appropriate for your intercompany transactions.
Audit Representation
Representation before tax authorities during transfer pricing assessments, including preparation of written submissions and attendance at hearings.
APA Assistance
Support for Advance Pricing Agreement applications to secure upfront certainty on transfer pricing methodology with Indian tax authorities.
MAP Support
Assistance with Mutual Agreement Procedure filings to address double taxation arising from transfer pricing adjustments in India.
Why Thorough TP Compliance Matters
Robust transfer pricing documentation does more than satisfy a regulatory requirement. It creates clarity, reduces uncertainty, and positions your India operations on solid ground.
- Audit-ready documentation that addresses questions before they arise
- Pricing policies grounded in functional and economic substance
- Reduced exposure to adjustments, penalties, and protracted disputes
- A clear record supporting consistent positions across jurisdictions
- Preparedness for an environment of increasing global tax transparency
How We Work Through a TP Engagement
Step 1
Understanding Your Structure
We map your group's legal entities, intercompany flows, and each entity's functions, assets, and risks—the factual foundation on which all transfer pricing analysis rests.
Step 1
Understanding Your Structure
We map your group's legal entities, intercompany flows, and each entity's functions, assets, and risks—the factual foundation on which all transfer pricing analysis rests.
Step 2
Selecting the Right Method
Based on the nature of transactions and available data, we identify the most appropriate TP method and locate comparable transactions to establish a defensible arm's length range.
Step 2
Selecting the Right Method
Based on the nature of transactions and available data, we identify the most appropriate TP method and locate comparable transactions to establish a defensible arm's length range.
Step 3
Building the Documentation
We prepare Local File, Master File, and supporting schedules—structured to meet regulatory specifications and articulate the reasoning behind your pricing clearly.
Step 3
Building the Documentation
We prepare Local File, Master File, and supporting schedules—structured to meet regulatory specifications and articulate the reasoning behind your pricing clearly.
Step 4
Filing & Ongoing Support
We assist with timely filing of Form 3CEB and related filings, and remain available for representation during assessments, appeals, or competent authority proceedings.
Step 4
Filing & Ongoing Support
We assist with timely filing of Form 3CEB and related filings, and remain available for representation during assessments, appeals, or competent authority proceedings.