Cross-Border Transfer Pricing Advisory in India for Multinational Companies

With deep expertise in Indian transfer pricing law, sector-specific insights, and a global mindset, A2 Consultants is a trusted partner for foreign companies navigating the complexities of international tax compliance in India. Whether you’re a SaaS company, manufacturing group, service provider, or IP-owning entity, we ensure your transfer pricing strategy is not only compliant but also efficient and defensible. Let us help you turn a regulatory requirement into a competitive advantage.

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Our services in Cross-Border Transfer Pricing Advisory in India for Multinational Companies

Transfer Pricing Advisory and Documentation Services in India

Transfer Pricing Advisory and Documentation Services in India

In today’s increasingly globalized economy, transfer pricing has become one of the most complex and scrutinized areas of international taxation. A2 Consultants provides end-to-end transfer pricing advisory and compliance solutions to foreign companies, multinational enterprises (MNEs), and cross-border joint ventures operating in India. We help ensure that intercompany transactions meet Indian regulatory requirements while aligning with OECD guidelines and international best practices.

At A2 Consultants, we understand that pricing arrangements between related parties can trigger tax audits and adjustments if not properly documented and justified. Our team of seasoned professionals, including chartered accountants, economists, and legal experts, offers practical, defensible, and industry-specific advice tailored to your business model and transaction profile.

Our Core Transfer Pricing Services Include:

Transfer Pricing Risk Assessment & Planning:
We help foreign businesses assess their current intercompany transactions for tax and regulatory risk. Our planning support includes structuring transactions to align with the arm's length principle while minimizing the potential for double taxation or regulatory penalties.

Functional and Economic Analysis:
We carry out comprehensive functional, asset, and risk (FAR) analyses to map the roles and contributions of each related entity. We also identify the most suitable transfer pricing method for your transactions in line with the Income Tax Act and OECD guidelines.

Benchmarking Studies:
Our team conducts robust benchmarking studies using Indian and international databases to determine arm’s length pricing for various transactions, including sale of goods, provision of services, IP licensing, cost sharing, management fees, and more.

Transfer Pricing Documentation (Local File & Master File):
We prepare accurate and timely documentation, including the Local File and Master File, in compliance with Indian TP regulations under Rule 10D. This helps mitigate the risk of penalties and demonstrates transparency to Indian tax authorities.

Transfer Pricing Returns (Form 3CEB):
We assist in the preparation and filing of Form 3CEB, which must be certified by a Chartered Accountant, disclosing international and specified domestic transactions.

Advance Pricing Agreements (APA) Support:
A2 Consultants helps eligible foreign companies evaluate, apply for, and negotiate bilateral or unilateral APAs with Indian tax authorities to gain long-term pricing certainty and reduce audit exposure.

TP Audit Representation & Dispute Resolution:
In case of scrutiny or reassessment, we represent clients before the Indian tax department and appellate authorities, providing documentation, explanations, and negotiation support to minimize tax adjustments and litigation risks.

 Compliance with BEPS and Country-by-Country Reporting (CbCR):
For MNE groups that meet the threshold, we assist in preparing and submitting CbCR reports in line with Indian and OECD Base Erosion and Profit Shifting (BEPS) Action 13 requirements.

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