Transfer Pricing
Transfer price is the price at which two divisions of the same company supply goods or services or labour to each other, assuming that both divisions are separately managed profit centres.
This allows the establishment of the price range for the goods and services interconnected among subsidies, affiliates and the companies that most commonly control and are part of a similar bigger enterprise.
Transfer pricing also leads to tax savings for corporations and through tax authorities that can claim for their contest.
What are some methods to determine the arm’s length price?
Section 92C of the Act has prescribed six methods to compute the arm’s length price which are selected based on the nature of transactions and availability of comparable details. The methods are:-
- Comparable uncontrolled price method (CUP);
- Resale price method (RPM);
- Cost plus method (CPM);
- Profit split method (PSM);
- Transactional net margin method (TNMM) and
- Such other method as may be prescribed by the Board
The ALP of any transaction can be determined by using any one of the prescribed methods that is the most appropriate for the transaction in question.
Transfer Pricing Documentation & Compliances
- Preparation of detailed transfer pricing documentation relating to international and specified domestic transactions as required u/s 92D read with Rule 10D of the Rules
- Issuance of Accountant’s Report / Transfer Pricing Certification (Form 3CEB) as required u/s 92E read with Rule 10E of the Rules
- Assistance in Preparation and submission of Master File and Country by Country reports (CBCR) in accordance with OECD's BEPS Action Plan 13

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- We engaged in managing clients' domestic and international transfer pricing transactions
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- Our transfer pricing services include transfer pricing studies, documentation, policy determination, determination of arm's length price (ALP) in accordance with Safe Harbor Rules (SHR), country-by-country (CbC) reporting, Advance Pricing Agreement (APA), transfer pricing certification (Form 3CEB), and many more.
- We work closely with our clients to ensure that they have a comprehensive understanding of the valuation process
- Provide accurate and reliable valuations that meet their specific needs.