International tax practice
Related-party pricing that holds up.
Every transaction with an associated enterprise is a position you may one day have to defend. We build the documentation, benchmarking and strategy that make that defence routine instead of desperate.
Compliance & documentation
- Transfer pricing study — functional analysis, method selection and economic analysis, documented to survive scrutiny
- Form 3CEB — certification and filing for international and specified domestic transactions
- Master File & CbCR — group-level documentation and country-by-country reporting where thresholds apply
Planning & benchmarking
The best transfer pricing outcomes are designed, not defended. We benchmark margins against reliable comparables before the year closes — so pricing policies for goods, services, royalties and financing are set inside defensible ranges from the start, and intercompany agreements say what the economics actually are.
Defence
- TPO proceedings — submissions, comparability arguments and representation through the assessment
- DRP & appeals — objections drafted and argued; positions carried into the appellate forums
A transfer pricing adjustment rarely visits once — the same issue returns every open year, with interest and penalty exposure attached. Documentation done properly the first year is the cheapest insurance in international tax.
Questions
Frequently asked
Any enterprise transacting with associated enterprises across borders — and domestic groups with specified domestic transactions above thresholds. If you buy from, sell to, borrow from or pay royalties to a related party abroad, Form 3CEB and documentation obligations almost certainly apply.
Penalty exposure, and a much weaker position in assessment — without contemporaneous documentation, the TPO's comparables tend to win by default. Documentation is the defence; it just has to exist before the dispute.
Yes. We review the existing study, identify the weak points, and build the strongest available defence for TPO and DRP proceedings.
Usually yes — the obligation follows the related-party transaction, not the size of the Indian entity. Cost-plus service entities are among the most frequently scrutinised.
Next step
Review your related-party exposure.
One look at your intercompany transactions and we'll tell you what's defensible, what isn't, and what to fix before year-end.