Transfer Pricing Services

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
 
     
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