What is Transfer Pricing (TP)?

With the increased involvement of international corporations in India’s economic activity, new and complex concerns have arisen from transactions between connected entities within the global corporation. To address this, the Indian Income Tax Act was amended in 2001 to include transfer pricing regulations. Transfer pricing is an accounting practice that seeks to ensure that profits are allocated appropriately between different subsidiaries or divisions of a company in different countries, while taking local tax laws and regulations into account.
These regulations adhere to OECD norms and include a variety of transfer pricing mechanisms and documentation processes, as well as significant penalties for non-compliance.

Significance of TP

With the increased involvement of international corporations in India’s economic activity, new and complex concerns have arisen from transactions between connected entities within the global corporation. To address this, the Indian Income Tax Act was amended in 2001 to include transfer pricing regulations. Transfer pricing is an accounting practice that seeks to ensure that profits are allocated appropriately between different subsidiaries or divisions of a company in different countries, while taking local tax laws and regulations into account.


These regulations adhere to OECD norms and include a variety of transfer pricing mechanisms and documentation processes, as well as significant penalties for non-compliance.

Services HNHACA offers-


    • Pre-assessments & real time planning


    • Strategy in setting up/restructuring complex cross-border transactions


    • Preparation of TP documentation for penalty protection (TP Study, Benchmarking analysis, Master file and Country by Country Report)


    • Preparation of TP documentation for penalty protection (TP Study, Benchmarking analysis, Master file and Country by Country Report)


    • Guidance on primary and secondary adjustments


    • Optimizing TP margins


    • Advising on the negotiation and implementation of Advance pricing agreements (APAs) with tax authorities


    • TP related due diligence reports


    • Representing clients at various stages and forums of dispute resolution


    • Conducting TP audit and issuance of accountant’s report (Form 3CEB)


    • Aiding in the application of safe harbor provisions (Form 3CEFA and Form 3CEFB)

TDS on Outward Remittances

TDS (Tax Deducted at Source) is a tax collection mechanism in which tax is deducted by the payer at the time of making payment to the payee. If a person is making a payment to a non-resident or a foreign company, they may be required to deduct TDS as prescribed by the Income Tax Act, 1961. It is important to note that TDS on outward remittances must be deposited with the government within a specified time frame, failing which, the payer may be liable to pay interest and penalties.

Services HNHACA offers-

Concrete guidance on TDS applicability considering DTAA and other relevant laws

Hand holding w.r.t compliances:

  • TDS returns and issuing TDS certificates
  • 15CA, Form 15CB, Form 15CC, Form 10F etc.

Auditing TDS compliances

Taxation of Expatriate

An expatriate is a person provisionally residing and employed in a different country while being citizen of his native land. The taxation of such expat employees requires a slightly modified computation than the tax computed for a normal resident employee of an Indian organization.

Services HNHACA offers-

Application and acquiring a TRC for residents in India (form 10FA and 10FB)
Guidance and aid in navigating the complex tax laws and regulations of different countries
Assistance in preparing and submitting the essential documents for obtaining a TRC

TDS on properties of NRIs

When a resident buys property from an NRI, she/he must deduct TDS at 20% if the property has been held for more than two years and at 30% if the property is being sold within two years

Services HNHACA offers-

  • Ensuring compliance with Indian tax laws and follow TDS requirements
  • Assisting in application for PAN
  • Obtaining a lower tax deduction certificate (Form 13)
  • Computation of capital gains
  • Advice on tax exemptions on capital gains
  • Repatriation of proceeds (Form 15CA and Form 15CB)
  • Hand holding in claiming foreign tax credit (FTC)