Transfer Pricing

Compliance meets strategy across borders.

Transfer Pricing refers to the pricing of goods, services, and intellectual property exchanged between related entities across international borders.

WHY IT MATTERS

Incorrect or poorly documented transfer pricing can trigger tax audits, financial penalties, and legal disputes. Tax authorities across jurisdictions increasingly require businesses to justify pricing policies with detailed documentation and robust economic analysis. Without proper transfer pricing compliance, companies face the risk of double taxation, tax authority challenges, and prolonged litigation. Transfer pricing is not just about meeting compliance—it’s about aligning financial operations with global tax strategy. Businesses that proactively manage their transfer pricing strategy are better equipped to handle scrutiny, optimize cross-border taxation, and build investor confidence. With the rise of BEPS (Base Erosion and Profit Shifting) initiatives, governments are sharing more data than ever before, making transparency and documentation more critical than ever.

PROBLEM & PROTECTION

When transfer pricing is not properly managed, businesses can face tax reassessments, delayed cross-border payments, strained relationships with tax authorities, and penalties that cut into profits. A lack of appropriate documentation or inconsistent application of pricing methods may result in severe regulatory consequences, especially in jurisdictions that mandate country-by-country reporting and detailed transaction records. To protect against these risks, companies must adopt a proactive transfer pricing framework. We help clients design and implement robust transfer pricing policies, document all intercompany transactions, and ensure consistency with international standards. We support businesses in audit situations, help secure Advance Pricing Agreements (APAs), and build defensible documentation that withstands regulatory scrutiny.

WHAT WE DO

Transfer Pricing Documentation
And Compliance

We prepare comprehensive documentation to support intercompany transactions and ensure regulatory compliance. This includes economic and functional analyses, benchmarking studies, and pricing justifications. We also ensure timely, accurate submission of master file, local file, and country-by-country reports.

Intercompany Transaction
Pricing Analysis

We analyze intercompany transactions—covering goods, services, royalties, and loans—to ensure arm’s length pricing. Our team performs benchmarking using global databases and conducts FAR (functions, assets, risks) analysis to select appropriate transfer pricing methods.

Advance Pricing Agreements
(APA) And Dispute Resolution

We assist clients in negotiating Advance Pricing Agreements (APAs) to secure certainty on transfer pricing. Our services cover APA application preparation, representation, and end-to-end negotiation management. We also support clients during audits, appeals, and Mutual Agreement Procedures (MAPs) to defend transfer pricing positions.

Cross-Border Tax Strategy And
Risk Management

We design tax-efficient intercompany transaction structures that comply with local and international transfer pricing rules. Our advisory mitigates risks of double taxation, permanent establishment, and withholding taxes, ensuring pricing reflects economic substance and withstands regulatory scrutiny.

BEPS And OECD Compliance
Advisory

We help clients align transfer pricing practices with OECD’s Base Erosion and Profit Shifting (BEPS) action plans. Our services include preparing country-by-country reporting, master file, and local file in compliance with OECD guidelines, and assessing BEPS impact to update documentation and policies accordingly.