USA · Service
Arm’s-length pricing and documentation for India–US groups — intercompany charges set and defended under both IRS and Indian transfer-pricing rules.
When a US parent and an Indian subsidiary, or the reverse, transact, both tax authorities scrutinise the price. We set arm’s-length pricing for services, IP and cost-sharing, document it to US and Indian standards, and reconcile the two so the same intercompany charge is not attacked from both sides.
Arm’s-length policies for services, IP and cost-sharing.
Comparables that satisfy US and Indian standards.
Documentation aligned to IRS requirements.
Master file, local file and accountant’s report where due.
Agreements that match the pricing and the conduct.
Defence if either authority challenges the price.
We identify intercompany flows both ways.
We set and benchmark arm’s-length charges.
We prepare US and Indian documentation.
We support review in either country.
We set intercompany pricing that satisfies the IRS and the Indian authorities at once — documented so neither side can pick it apart.
Client identities withheld for confidentiality; outcomes described in general terms.
Cost-plus charges for an Indian development arm benchmarked and documented both sides.
Defensible both-country filePricing and agreements corrected so the paperwork matched the actual flows.
Pricing and contracts alignedBook a consultation with our remote US Desk to set and document India–US intercompany pricing for both authorities.
Speak with a Partner →