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Transfer Pricing Documentation
Transfer Pricing Documentation
Transfer pricing documentation and benchmarking
If your Indian entity transacts with a group company abroad — a service fee, a management charge, a royalty, an intercompany loan, a cost recharge — you have a transfer pricing obligation, and the documentation has to exist contemporaneously. Assembling it after a notice arrives is both expensive and unconvincing.
We prepare the documentation as an annual process: the functional analysis, the benchmarking, the study, and the data pack that supports the Form 3CEB certification.
What’s included
1. Mapping and characterisation of all international and specified domestic related-party transactions
2. Functional, asset and risk (FAR) analysis, with management interviews
3. Selection of the most appropriate method — CUP, RPM, CPM, TNMM, PSM — with reasoning
4. Benchmarking study using [[ recognised databases ]], with a documented search strategy, rejection matrix and comparables set
5. Arm’s-length range computation and the entity’s position within it
1. Local File preparation in the format required under Rule 10D
2. Master File (Form 3CEAA) and CbCR notification (Form 3CEAC) support where thresholds are met
3. Data pack and schedules for Form 3CEB [[ the accountant’s report is certified by a Chartered Accountant; we prepare the underlying documentation ]]
4. Intercompany agreement review against the actual conduct of the parties
5. Year-end adjustment computation and secondary adjustment implications
6. Documentation support for transfer pricing assessments and appeals
Who This Is For
Indian subsidiaries of foreign groups, Indian companies with overseas subsidiaries, captive service centres, and any entity crossing the specified domestic transaction thresholds.