Transfer Pricing

With the world wide trade happening so intensely all around the Globe these days, the concept of Transfer Pricing has gained much importance. Transfer pricing is one most important entity that the tax officials and the revenue authorities look up to.

The rapid growth in the trade market and wide International transactions, Transfer Pricing plays a key role in creating profit allocation method by the multinational enterprises to set its profit limit before paying tax to the countries where it enters to do its business.

Transfer pricing is one of the major tools to lessen the burden of paying heavy corporate tax.  Also called as Base Erosion and Profit Shifting (BEPS).

The guidelines and rules regulated by Organisation for Economic Cooperation Development (OECD). Many International enterprises have adopted these guidelines, though with little modification made by many countries.

We assist our clients with the rules and guidelines regulated by ( OECD ) as well as,  as per the regulations laid by Indian Income tax-Law to provide them customised corporate wise support and help them with Inter-company transfer pricing policies to maintain the pricing within the Arms Length Price.

Organisational Challenges:

Any enterprise faces different challenges when it comes to documenting various entities for Audit purposes. We closely work with our clients outlining them the legalities on various factors.


When it comes to the tax payers, many such white paper documentation has to be fulfilled at different stages. This needs to be documented in alignment with the global jurisdiction.


Providing corporate wise support, making market analysis, planning and documenting of transfer pricing policies and procedures.

Advanced Pricing Agreements (APAs)

Keep vigilant eye on managing cross border effective tax rate during a business expansion or transformation.

Economic Benchmarking

Analysis and mapping on allocation of the values across the entire supply chain.

Analysis of Cost Sharing Arrangements

Knowing through various study and being abreast with  new rules and regulations formed by the tax authorities and making improvements on transfer pricing if it is sufficient or needs improvement.

IP Valuation and Migration

Managing transfer pricing and the risk factors concurrently.

Analysis of Intercompany Loans

Explain and defend or transfer pricing to the tax authorities.

Financial Services Transfer Pricing

Managing and facing challenges that arise out of domestic transfer pricing rules.

Out of Range Assessment/Special Factors

Managing and assisting clients on compliance under the companies Act 2013 / Clause 49 of SEBI listing guidelines.

Economic Support for Controversy, Audit Defense and Litigation

Making reports and documenting country by country on Base Erosion & Profit Shifting and taking initiative for entrepreneurs to run their business smoothly.

Our Services:

  • We are all aware of the existing scenario. The guidelines, the strict rules imposed, complications involved in fixing transfer price, to handle sharp audits and inspections by tax authorities. It is mandatory to maintain fool proof transfer pricing documentation and defence files for every branch in different territories with Indian Custom regulation.
  • Business transformation is a complicated process. A broad set up that concentrates on all these issues is the key.
    1. To provide effective value chain management that will work towards increasing efficiency of the organisation.
    2. To provide effective insights on legal-tax for sustainable financial growth.
  • To be able to face the challenges by the Tax authorities it is very essential to keep the transfer pricing policies transparent by documenting and maintaining comprehensive policies that go in line with the business strategies.
  • The organisation runs through strict business environment and controversy and legal disputes come as part of it. To keep it transparent the tax payers require a certain degree of certainity in paying tax. Advance Pricing Agreement (APA) helps a big deal in ensuring successful outcome.
  • For smooth running of the organisation it is necessary that the company signs contract agreement between two parties engaged in the business. A systematic set up of governance framework that determines Arm's Length Price as per companies Act 2013 / clause 49 of the SEBI listing guidelines.

At iMaster, our professionals will take you through our six-step managed outsourcing process, including:

  • Developing a Work Plan
  • Information Gathering
  • Arm's Length Analysis
  • Client Project Review
  • Project Completion
  • Sign Off

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