Transfer Pricing Advisory
Expert Consulting — Serving Clients Across India
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.