Transfer Pricing and Advisory Services

In an era of heightened global scrutiny and evolving transfer pricing regulations, businesses engaged in cross-border or intercompany transactions must navigate complex legal and operational frameworks. At Pratapkaran Paul & Co, our Indian transfer pricing advisory services are tailored to help multinational corporations and domestic groups comply with Sections 92 to 92F of the Income Tax Act, 1961, and Rules 10A–10E. We craft defensible transfer pricing policies, conduct rigorous FAR (Functional, Asset, Risk) analysis, and offer proactive BEPS advisory, including support for Master File and Country-by-Country (CbC) reporting as per OECD guidelines. From audit risk mitigation, our experts ensure transparent, arm’s-length pricing, minimizing exposure to transfer pricing adjustments, penalties, and litigation. Whether you're dealing with intangible asset transfers, guarantees, intra-group services, or R&D cost allocation, we offer a full suite of services—including Form 3CEB certification, international benchmarking, and documentation compliance under s. 92D / Rule 10D—to support your strategic and regulatory needs.