Strategic compliance and advisory to optimize cross-border transactions while staying audit-ready.
Transfer Pricing (TP) as a specialized niche because it’s critical for multinational businesses and Indian entities with cross-border or inter-company transactions.
Why It Matters
With globalization, businesses frequently engage in cross-border and inter-company transactions — sale of goods, provision of services, royalties, cost-sharing, loans, or intangibles. The Income Tax Department closely monitors these to ensure they are carried out at Arm’s Length Price (ALP).
Non-compliance or weak documentation in Transfer Pricing can lead to:
- Heavy adjustments and penalties
- Prolonged tax litigations
- Reputation risks in audits and investigations
- Double taxation without relief
At FinnovateAI, we provide comprehensive Transfer Pricing solutions that not only meet compliance requirements but also help in tax-efficient structuring of international and domestic related-party transactions.
Our Services
Transfer Pricing Documentation
- Preparation of local files & master files as per Indian TP regulations
- Maintenance of inter-company agreements & benchmarking analysis
- Country-by-Country Reporting (CbCR) for global groups
Benchmarking & Comparability Analysis
- Selection of most appropriate TP method (CUP, RPM, CPM, TNMM, PSM)
- Industry-specific comparable search using global databases
- Functional, Asset & Risk (FAR) analysis for inter-company transactions
Transfer Pricing Compliance & Filings
- Form 3CEB preparation & filing under Section 92E
- Advisory on secondary adjustments & APA (Advance Pricing Agreements)
- Representation during audits, assessments & TP litigation
Strategic Advisory
- Designing tax-efficient inter-company structures
- Advisory on cross-border financing, cost-sharing & royalty models
- Risk assessment & dispute management with tax authorities
Why Choose FinnovateAI?
- CA & TP Specialist-Led - Expert-led TP documentation, benchmarking, and dispute resolution
- Global Standards - Use of international TP databases & OECD-aligned methodologies
- Audit-Ready Compliance - Defensible documentation to withstand IT scrutiny
- Proactive Risk Management - Advisory to prevent future disputes
- Integrated Approach - Alignment with accounting, tax planning & corporate structuring
Our Process
- Transaction Mapping - Identify and analyze related-party transactions
- FAR & Benchmarking - Detailed functional and comparability analysis
- Documentation & Reporting - Prepare 3CEB, local file, master file, CbCR
- Authority Representation - Handle TP audits & assessments
- Strategic Advisory - Optimize future structures for tax efficiency
Who Needs It?
- Multinational Companies (MNCs) with cross-border transactions
- Indian subsidiaries of foreign companies
- Domestic groups with significant inter-company dealings
- Startups scaling globally with IP licensing or royalty models