Transfer Pricing Advisory at a glance
Accorg Consulting advises clients on Transfer Pricing Advisory with a combined legal and financial strategy, focused on fast risk assessment, clean documentation, and practical next steps.
- Direct assessment of facts, documents, and legal exposure before strategy is finalized.
- Representation is aligned to both legal risk and commercial outcome, not filing for the sake of filing.
- Support is structured for founders, directors, lenders, creditors, and business owners who need clarity quickly.
When clients usually contact us
Transfer Pricing Advisory in India
Transfer pricing (TP) is one of the highest-risk areas of international taxation for Indian multinationals and foreign subsidiaries. With Indian tax authorities increasingly scrutinising intra-group transactions, robust TP documentation is not optional — it is essential to avoid penalties of up to 2% of the transaction value.
Accorg Consulting's TP practice, led by CA Chaitanya (8 years, Qatar & Singapore experience), combines technical benchmarking expertise with deep understanding of the OECD Guidelines, Indian TP Regulations (Section 92–92F of Income Tax Act), and global TP trends.
Our Transfer Pricing Services
TP Documentation & Benchmarking
- Master File (Form 3CEAA) and Local File preparation
- CbCR (Country-by-Country Report) — Form 3CEAD
- Functional Analysis — FAR (Functions, Assets, Risks)
- Economic benchmarking using Prowess, TP Catalyst databases
- Most Appropriate Method (MAM) selection and justification
Advance Pricing Agreements (APAs)
- Unilateral APA application preparation and CBDT negotiations
- Bilateral and Multilateral APA coordination
- APA rollback applications
TP Litigation & Dispute Resolution
- Representation before TP Officer (TPO) and DRP
- ITAT transfer pricing appeals
- Mutual Agreement Procedure (MAP) under DTAA
Intra-Group Transaction Structuring
- Management fee, royalty, and technical service fee structuring
- Loan and guarantee pricing under TP regulations
- Cost sharing arrangement (CSA) design
- Business restructuring — TP implications and risk migration
Industries We Serve
Manufacturing, IT/ITeS, pharmaceuticals, FMCG, financial services, and infrastructure — with specific experience in India–UAE, India–Singapore, and India–US cross-border structures.
Documents we usually review first
- Company incorporation records, board resolutions, and shareholder documents.
- Contracts, invoices, notices, ledgers, email trail, and supporting correspondence.
- Financial statements, bank papers, tax filings, or regulatory submissions linked to the dispute.
- Any prior legal notice, reply, order, appeal, or settlement draft.
How the engagement typically moves
- Initial review of facts, documents, forum, and urgency.
- Issue spotting, legal position mapping, and commercial risk assessment.
- Drafting, filing, reply, negotiation, or hearing preparation based on the matter stage.
- Follow-through on interim relief, final order strategy, or settlement execution.
Strategic checkpoints
- Clarify the exact trigger, forum, timeline, and commercial objective before action starts.
- Review documentary strength before any formal filing or reply is finalized.
- Choose a path that balances legal defensibility with speed, cost, and settlement leverage.
Why Choose Accorg Consulting
- Integrated legal and CA-led advisory model for disputes that have both legal and financial consequences.
- Experience across NCLT, IBC, GST, FEMA, DRT, banking, and corporate conflict matters.
- Track record highlights used across the site: 800+ court matters handled and pan-India advisory coverage.
Frequently Asked Questions
Below FAQs are included to cover follow-up questions Google and AI answer engines commonly expand on for this service.