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India › Transfer Pricing

India · Service

Transfer Pricing & Benchmarking

Documentation, benchmarking and defence for related-party transactions — built to the standard an assessing officer cannot easily dislodge.

Overview

Defensible pricing, documented before it is questioned.

Related-party transactions draw scrutiny precisely because they are easy to adjust. We prepare arm’s-length documentation, run defensible benchmarking studies and represent the position through assessment — so that intercompany pricing is supported by analysis, not assertion.

Indian companies with foreign group entities or associated enterprises
Groups with intercompany services, royalties, financing or goods flows
Businesses facing a transfer-pricing adjustment or reference to the TPO
Multinationals needing master-file and local-file compliance
What’s Included

The full transfer-pricing cycle.

TP Documentation

Local file, master file and the prescribed Indian TP study, prepared to survive scrutiny.

Benchmarking Studies

Comparable selection and arm’s-length-range analysis using recognised databases.

Method Selection

TNMM, CUP, cost-plus and others applied to the facts, with reasons documented.

Form 3CEB

Accountant report certification and filing for international and specified domestic transactions.

TPO Representation

Defence before the Transfer Pricing Officer and through assessment and appeal.

APA & Planning

Advance-pricing-agreement support and forward planning for recurring flows.

How We Work

Benchmark, document, defend.

01

Map

We identify every associated-enterprise transaction and its character.

02

Benchmark

We run the comparability and arm’s-length analysis and select the method.

03

Document

We prepare the study, master file and Form 3CEB to filing standard.

04

Defend

We represent the position before the TPO and on appeal if adjusted.

Why LexVerge

A study is only as good as its defence.

Local FileMaster FileForm 3CEBTNMM / CUPBenchmarkingTPO AssessmentAPASpecified Domestic TransactionsMLIOECD Guidelines

We write the documentation knowing we may have to argue it — so it is built to be argued.

Representative Outcomes

Anonymised mandates from this practice.

Client identities withheld for confidentiality; outcomes described in general terms.

Adjustment Defence

TPO adjustment contested on comparables

Benchmarking set re-argued and the method defended through assessment with a built appeal record.

Position defended on the merits
Recurring Flows

Documentation programme for an intercompany services model

A repeatable master-file and local-file process established for annual compliance.

Annual compliance made repeatable
FAQ

Transfer pricing, answered.

Do we need a transfer-pricing study if our foreign transactions are small?
If you have international transactions with associated enterprises, documentation and Form 3CEB obligations can apply regardless of size. We assess applicability and scope it proportionately.
Can you defend an adjustment already proposed by the TPO?
Yes. We review the comparables and method used, build the counter-analysis and represent the position through assessment and appeal.
India · LexVerge

Make your intercompany pricing defensible.

Book a consultation to scope your documentation, benchmarking and Form 3CEB obligations.

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