International Transfer Pricing every border, every related-party rupee.
Cross-border transfer pricing advisory for multinational groups — intercompany policy, OECD BEPS alignment, Pillar Two readiness, Mutual Agreement Procedure (MAP), and Advance Pricing Agreement (APA) support.
International transfer pricing covers every cross-border transaction between associated enterprises — sale of goods, provision of services, royalty, intra-group financing, cost contribution arrangements, and reorganisation of value chains. The Indian rules are aligned with OECD principles, but each jurisdiction has its own nuances.
The BEPS project has reshaped global TP. Substance-over-form, value creation, intangibles ownership, and risk allocation are now central to every TP defence. Pillar Two minimum tax adds another dimension — top-up taxes can apply where group effective tax rates in a country fall below 15%.
We advise multinational groups on the Indian leg of their international TP — aligning Indian operations with global TP policy, designing intercompany agreements that hold up in India, running MAP for double-taxation resolution, and concluding APAs (unilateral or bilateral) for forward-looking pricing certainty.
Our International Transfer Pricing Services
Global TP Policy Alignment
Alignment of group TP policy with Indian rules and judicial trends.
Intercompany Agreements
Drafting and review of cross-border intercompany agreements.
Royalty & FTS Structuring
Tax-efficient royalty and FTS structuring with DTAA optimisation.
Intra-Group Financing
Arm's length pricing of intra-group loans, guarantees, and cash pools.
BEPS & Pillar Two
BEPS alignment and Pillar Two GloBE rule readiness.
MAP
Mutual Agreement Procedure for resolving cross-border TP disputes.
APA — Unilateral & Bilateral
Unilateral and bilateral Advance Pricing Agreements with CBDT.
Cross-Border Restructuring
TP analysis of business restructuring, IP migration, and value chain redesign.
Our Approach
Group Mapping
Cross-border value chain and AE relationships mapped.
Policy Review
Global TP policy reviewed against Indian law and BEPS standards.
Agreement Alignment
Intercompany agreements aligned with policy and substance.
Documentation & Filings
Local File, Master File, and CbCR aligned across countries.
Certainty Tools
APA or MAP pursued for forward-looking or retroactive certainty.
Why It Matters
Frequently Asked Questions
Pricing of cross-border transactions between associated enterprises in line with arm's length principle.
OECD's Base Erosion and Profit Shifting project to align taxation with value creation.
OECD framework imposing a 15% global minimum effective tax on large MNE groups.
Mutual Agreement Procedure between competent authorities to resolve cross-border tax disputes.
An Advance Pricing Agreement that fixes TP methodology with the tax authority for future years.
Cross-Border TP Strategy?
Get the Indian leg of your global transfer pricing done right — policy, documentation, MAP, and APA — by specialists who navigate OECD and Indian rules together.
Plan My International TP or call +91 9819 000 511