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Transfer Pricing Services

Cross-border compliance for your India operations.

Overview

What you get

For US, UK, and European multinationals with India subsidiaries or related-party transactions, our transfer pricing practice ensures arm's-length compliance across jurisdictions. We prepare TP documentation, benchmarking studies, Country-by-Country Reports, and defend pricing positions before Indian tax authorities.

If your US or UK business operates an India subsidiary, captive center, or shared services hub, transfer pricing is one of your highest compliance risks. Indian tax authorities are among the most aggressive globally. DMCGlobal Services LLP helps you design defensible TP policies, working in close collaboration with our India Tax & GST Compliance team.

We prepare Local File and Master File documentation aligned with OECD BEPS guidelines, and manage TP audits before Indian TPOs. We coordinate with your home-country advisors to ensure consistency with US/UK filings, preventing mismatches that trigger double taxation. This runs parallel to our Cross-Border Tax Advisory.

Our transfer pricing studies leverage advanced databases to establish robust benchmarking. For strategic deal structuring or corporate buy-outs, we integrate these evaluations with our M&A Transaction Advisory and registered Financial Valuations.

Key Offerings

TP Documentation & Benchmarking

Local File, Master File, and CbCR preparation aligned with OECD BEPS and Indian TP regulations. Benchmarking using Prowess, Capitaline, Bureau van Dijk, and RoyaltyStat databases.

Intercompany Agreement Design

Drafting and reviewing intercompany service agreements, cost-sharing arrangements, and licensing agreements to support arm's-length pricing.

Advance Pricing Agreements (APA)

End-to-end support for Unilateral, Bilateral, and Multilateral APA applications with CBDT — providing long-term certainty for your intercompany pricing.

TP Audit Defence

Representation before Indian Transfer Pricing Officers, Dispute Resolution Panels, and ITAT — with a strong track record of successful outcomes for multinational clients.

Country-by-Country (CbC) Reporting

Preparing global master files and local files aligned with BEPS Action Plan guidelines.

Safe Harbour Applications

Preparing and submitting transfer pricing declarations under government safe harbour rules.

Why DMCGlobal Services LLP?

We bridge the gap between your home-country advisors and Indian tax authorities — ensuring your transfer pricing is defensible on both sides of the border.

FAQs

Frequently Asked Questions

Why is Transfer Pricing critical for multinational companies with Indian subsidiaries?

Transactions between related entities (like a parent company charging or paying its subsidiary) must be at "Arm's Length." India requires strict annual transfer pricing audits (Form 3CEB) and imposes heavy penalties for non-compliance.

Which database do you use for Transfer Pricing benchmarking studies in India?

We utilize premium global and local databases, including Prowess, Capitaline, Bureau van Dijk (TP Catalyst), and RoyaltyStat, which are the standard databases relied upon by the Indian Income Tax Department.

What is the safe harbor rule for IT/ITES subsidiaries in India?

The Indian government offers safe harbor provisions for IT/ITES companies operating with operating margins between 17% and 18%, allowing subsidiaries to secure audit immunity on transfer prices if they meet the threshold.