Transfer Pricing Advisory & Study
Businesses with cross-border or specified domestic transactions between related entities are required under the Income Tax Act 1961 to price those transactions at arm’s length and maintain supporting documentation. Hegde Hegde and Associates LLP provides transfer pricing advisory and study services structured around these statutory requirements.
Partner reviewedDocumented processBengaluru office
Why Transfer Pricing Matters
Sections 92 to 92F of the Income Tax Act 1961 require that international transactions and specified domestic transactions between associated enterprises be priced at arm’s length. Non-compliance can result in adjustments to taxable income, interest, and penalties.
Beyond compliance, a properly conducted transfer pricing study supports the business in defending its pricing position during scrutiny, and provides management with a documented basis for related-party pricing decisions.
Why Businesses Need This Service
- Cross-border transactions with group entities, including sale of goods, services, royalties, or intra-group financing.
- Specified domestic transactions between related Indian entities exceeding prescribed thresholds.
- A need to benchmark existing related-party pricing against comparable market transactions.
- Upcoming transfer pricing audit or scrutiny requiring documented support for pricing positions.
- Restructuring of intercompany arrangements requiring a revised transfer pricing policy.
- First-time cross-border operations requiring a transfer pricing study to be conducted.
Our Approach
- 01
Assessment
Reviewing the client’s related-party transactions and existing pricing arrangements.
- 02
Planning
Selecting the applicable transfer pricing method and benchmarking approach.
- 03
Documentation
Preparing the transfer pricing study, including functional and economic analysis.
- 04
Execution
Conducting benchmarking analysis using appropriate databases and comparables.
- 05
CA Review
Independent review of the study and pricing conclusions.
- 06
Compliance Verification
Cross-checking documentation against Income Tax Act and Rules requirements.
- 07
Reporting
Delivery of the transfer pricing study report and Form 3CEB certification support.
- 08
Continuous Support
Ongoing monitoring of transfer pricing regulatory developments.
Scope of Services
- Transfer pricing study preparation, including functional, asset, and risk (FAR) analysis
- Benchmarking analysis and selection of comparable transactions
- Transfer pricing documentation as prescribed under Rule 10D
- Form 3CEB accountant’s report certification support
- Advisory on intercompany agreements and pricing policy design
- Support during transfer pricing assessments and scrutiny proceedings
- Advance Pricing Agreement (APA) advisory, where applicable
Business Benefits
- Reduced risk of transfer pricing adjustments, interest, and penalties.
- Documented support for related-party pricing positions during scrutiny.
- Improved clarity on intercompany pricing policy for management decision-making.
- Stronger audit and regulatory readiness for cross-border and domestic related-party transactions.
- Coordinated transfer pricing and international tax positions across the group.
Why Choose Hegde Hegde and Associates LLP
- Transfer pricing studies reviewed by a qualified Chartered Accountant before issuance.
- Transfer pricing advisory coordinated with our international taxation practice.
- Structured benchmarking methodology aligned with Income Tax Rules requirements.
- Documentation standards suited to scrutiny and assessment proceedings.
- Practical advisory grounded in current Indian transfer pricing jurisprudence.
Industries We Serve
Our transfer pricing engagements support technology and IT services companies with group cross-border transactions, manufacturing enterprises with intra-group supply arrangements, and startups with overseas holding or subsidiary structures.
Technology & IT services
D2C & e-commerce
Manufacturing
Startups & funded ventures
Professional services
NRI individuals
Healthcare
Real estate
Financial institutions
NGOs & trusts
Hospitality
Education
Our Process
Each stage produces a defined deliverable, and nothing is issued to a client before the Chartered Accountant review stage is complete.
- 01
Discovery
Understanding the client’s related-party transaction profile.
- 02
Assessment
Reviewing existing pricing arrangements and prior documentation.
- 03
Documentation Review
Identifying gaps against Rule 10D requirements.
- 04
Execution
Conducting the benchmarking analysis and preparing the study.
- 05
CA Review
Independent review of the study and conclusions.
- 06
Reporting
Delivery of the transfer pricing study and Form 3CEB support.
- 07
Ongoing Support
Continued monitoring of regulatory developments.
Frequently Asked Questions
The arm’s length principle requires that transactions between related or associated enterprises be priced as though the parties were unrelated, based on comparable market transactions.
International transactions between associated enterprises, and specified domestic transactions between related Indian entities exceeding prescribed thresholds, generally require transfer pricing documentation under the Income Tax Act.
Form 3CEB is an accountant’s report certifying the international and specified domestic transactions undertaken by a taxpayer and confirming that the prescribed documentation has been maintained.
Failure to maintain prescribed transfer pricing documentation can result in penalties under the Income Tax Act, in addition to potential adjustments to taxable income during assessment.
A transfer pricing study is generally prepared annually to reflect the transactions and comparable data for that financial year, and should be revisited whenever the nature or scale of related-party transactions changes materially.
Discuss Your Transfer Pricing Requirements
Whether you are conducting a transfer pricing study for the first time or reviewing an existing intercompany pricing policy, our team is available to discuss your specific requirement.
Content reviewed by CA Ramkumar Hegde, Partner, Hegde Hegde and Associates LLP.