International Transfer Pricing
If your business deals with overseas group entities, the tax authorities are already paying attention.
Any transaction between related parties across borders needs to be priced at arm’s length. If it’s not, the risk isn’t just technical non-compliance, it’s real money in the form of tax adjustments, penalties, and prolonged scrutiny.
At N D Savla & Associates, we help you get your transfer pricing right from day one and defend it when it matters.
What this really means for you
International transfer pricing applies when you have cross-border transactions with related parties, such as:
Import or export of goods
Provision of services (IT, management, support, etc.)
Intercompany loans or financing
Royalty, brand usage, or licensing arrangements
Cost-sharing or reimbursement structures
These transactions must be priced as if they were done between unrelated parties. If not, the tax department can rework your income, and that’s where problems begin.
Where businesses usually get stuck
Pricing is set commercially, but not documented properly
Agreements don’t match actual transactions
Benchmarking is outdated or missing
Transfer pricing reports are done just for compliance, not defense
This is exactly where most notices and adjustments come from.
Our Approach
We don’t just prepare a report at year-end. We work with you to make sure your structure actually holds up.
1. Transaction Mapping
We identify all international related-party transactions and evaluate applicability.
2. Method Selection & Benchmarking
We apply the right transfer pricing method and use reliable comparables to justify pricing.
3. Documentation (TP Study Report)
Preparation of robust transfer pricing documentation as required under Indian regulations.
4. Compliance Support
Filing of Form 3CEB and alignment with return filings.
5. Assessment & Litigation Support
If scrutiny arises, we help you defend your position with proper technical and practical backing.
Why Clients Work With Us
We focus on defensibility, not just paperwork
We understand how assessments actually work
We keep communication clear, no unnecessary complexity
We act early, so you don’t fix things under pressure
Who Should Consider This?
Companies with overseas subsidiaries or parent entities
Exporters and importers dealing with group companies
Startups receiving funding and cross-charging services
Businesses with royalty, licensing, or intercompany financing
F.A.Q.
It refers to pricing of transactions between related entities located in different countries, ensuring they are conducted at arm’s length.
It means the transaction price should be the same as what independent parties would agree to under similar conditions.
Yes. If you have international transactions with related parties, maintaining proper documentation is required under Indian tax laws.
It’s a report certified by a Chartered Accountant that needs to be filed for international (and specified domestic) transfer pricing transactions.
You may face income adjustments, penalties, and detailed scrutiny from tax authorities.
We handle the entire process, from structuring and benchmarking to documentation and assessment support, so your transactions are both compliant and defensible.
