Transfer Pricing Study the document that defends every related-party transaction.
End-to-end transfer pricing study under Rule 10D — industry overview, FAR analysis, intercompany agreement review, ALP method selection, benchmarking, and Local File documentation ready for assessment.
The transfer pricing study is the contemporaneous documentation that every Indian taxpayer with international or specified domestic transactions must maintain under Rule 10D. It is not optional, not a one-page memo, and not something that can be cobbled together after a notice arrives.
A well-built TP study tells a clear story — what the group does, who the associated enterprises are, what each entity contributes (functions, assets, risks), how related-party transactions flow, why a particular ALP method has been selected, and how the benchmarking supports an arm's length conclusion.
We prepare TP studies as litigation-ready documents. Each study covers industry overview, group structure, FAR analysis, transaction-wise method selection, comparable search and screening, financial adjustments, and conclusion. The final document is the same one we will defend in TP assessment if scrutiny arises.
Our Transfer Pricing Study Services
Industry & Group Overview
Detailed industry note and group structure with role of Indian entity.
FAR Analysis
Functions performed, Assets employed, and Risks assumed analysis.
Intercompany Agreements
Review of intercompany agreements for substance and consistency.
Method Selection
Choice and justification of CUP, RPM, CPM, PSM, or TNMM.
Comparable Search
Database search and qualitative screening of comparables.
Financial Adjustments
Working capital, capacity, and risk adjustments where applicable.
Local File Compilation
Final Rule 10D-compliant document with all required sections.
Year-on-Year Refresh
Annual refresh with updated financials and comparables.
Our Approach
Information Pack
Group structure, AE list, agreements, and financials collected.
FAR Workshop
Workshop with management on functions, assets, and risks.
Method & Search
ALP method finalised and comparable search executed.
Draft & Review
Draft TP study reviewed with client and adjustments made.
Final Documentation
Final Local File signed off and retained for assessment.
Why It Matters
Frequently Asked Questions
Contemporaneous documentation under Rule 10D defending arm's length pricing of related-party transactions.
Yes, for taxpayers crossing the ₹1 crore international transaction or ₹20 crore SDT threshold.
Analysis of Functions performed, Assets employed, and Risks assumed by each related party.
TNMM (Transactional Net Margin Method) is the most commonly applied method in India.
Annually, with updated financials, comparables, and any structural changes.
Need a Defendable TP Study?
Get a Rule 10D compliant transfer pricing study built for both filing and litigation defence — by Chartered Accountants who litigate TP for a living.
Build My TP Study or call +91 9819 000 511