USA › Transfer Pricing
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.
How Indian and UAE transfer pricing rules apply to the same intercompany transactions, which India-UAE structures attract scrutiny, and how to keep...
Read the guide →India-US CorridorGILTI Becomes NCTI: How US Tax Reaches Your Indian Subsidiary from 2026From 2026 GILTI is replaced by NCTI. How the US taxes the profits of an Indian subsidiary owned through a US parent, and what founders should model.
Read the guide →Income-tax Act 2025Income-tax Act 2025 Section Mapping for Cross-Border Work: Old vs New Sections and FormsThe 1961-to-2025 section and form map a cross-border practitioner needs: non-resident TDS, lower deduction, treaty relief, transfer pricing, reside...
Read the guide →Book a consultation with our remote US Desk to set and document India–US intercompany pricing for both authorities.
Speak with a Partner →