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Practice Areas

Transfer Pricing

TP documentation, benchmarking studies, APA applications, and representation before Transfer Pricing Officers for cross-border related-party transactions.

What is Transfer Pricing?

Transfer Pricing refers to the pricing of transactions between associated enterprises in different tax jurisdictions. Under the Income Tax Act, Section 92 to 92F, Indian companies must document and justify their intercompany pricing using the arm's length principle. Non-compliance can result in significant adjustments and penalties.

Scope of Our Services

  • TP documentation and master file / local file preparation
  • Benchmarking studies using TNMM, CUP, RPM, and PSM methods
  • Form 3CEB preparation and filing with the tax return
  • APA (Advance Pricing Agreement) applications — unilateral, bilateral, and multilateral
  • Safe harbour analysis and elections
  • TP audit support and representation before the Transfer Pricing Officer
  • Secondary adjustment and MAP (Mutual Agreement Procedure) assistance
  • Country-by-Country Reporting (CbCR) and Master File compliance

Why it matters: Non-compliance in this area carries significant penalties and regulatory exposure. Our team ensures you are always ahead of your obligations.

Our Transfer Pricing Process

01
Understand the client's business structure and related-party transactions for the year
02
Identify applicable transactions and select appropriate TP methods
03
Conduct economic benchmarking using reliable databases (Prowess, TP Catalyst)
04
Prepare TP documentation, local file, and Form 3CEB
05
File with the income tax return and assist during scrutiny assessment or TP audit

Related Expertise

International TaxationFEMA & RBIDTAA AdvisoryForm 15CA/CBCorporate Tax
Why DSMK

Why Choose Us for Transfer Pricing

📄
Big 4-Standard Documentation
TP reports structured to withstand scrutiny from the Transfer Pricing Officer and ITAT.
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Cross-Border Expertise
Deep experience with inbound and outbound transactions — royalties, management fees, loans, services.
⏱️
Timely Delivery
Form 3CEB has a hard statutory deadline. We ensure documentation is ready well before filing.
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End-to-End Support
From documentation to TP audit to appeals — we stay with you through the entire lifecycle.

Ready to Get Started?

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