International Taxation

Overview

With businesses expanding globally, transfer pricing has become one of the most scrutinized areas of international taxation.
At ND S Advisors, we provide comprehensive Transfer Pricing Advisory Services that help organizations comply with regulatory requirements while aligning intra-group pricing with global best practices.

Our focus is simple — ensuring that every cross-border or domestic related-party transaction meets the test of “arm’s length” under the Income Tax Act and OECD guidelines.

Our Transfer Pricing Services

Transfer Pricing Documentation

Preparation of detailed transfer pricing reports as per Rule 10D, including functional, economic, and benchmarking analyses. We ensure robust documentation that stands up to scrutiny during audits or assessments.

Transfer Pricing Planning & Structuring

Advisory on designing inter-company pricing models for goods, services, intangibles, and financing arrangements to achieve tax efficiency and compliance across jurisdictions.

Benchmarking Analysis

Comparative analysis using reliable databases to determine the most appropriate pricing method and ensure arm’s length compliance for all related-party transactions.

Domestic Transfer Pricing Compliance

Assistance with transfer pricing compliance for specified domestic transactions under Section 92BA, ensuring accuracy and timely filings.

Transfer Pricing Audit Support

Representation before the tax department during TP assessments, defending documentation and pricing positions with a data-backed, analytical approach.

Advance Pricing Agreements (APA)

Support in evaluating, negotiating, and obtaining unilateral, bilateral, or multilateral APAs with tax authorities to achieve long-term pricing certainty.

Master File & Country-by-Country Reporting (CbCR)

Preparation and filing of Master File (Form 3CEAA) and CbCR reports (Form 3CEAD) for multinational groups, in compliance with OECD BEPS Action Plan.

Litigation & Dispute Resolution

Representation before Transfer Pricing Officers, Dispute Resolution Panels, and appellate authorities to effectively resolve disputes and minimize adjustments.

Why Choose ND S Advisors

IT & ITES
Manufacturing & Trading
Pharmaceuticals & Healthcare
Financial Services
Consulting & Professional Services
Infrastructure & Real Estate

Industries We Serve

Multinational companies with operations in India
Indian companies investing abroad
Non-resident entities and individuals earning income from India
Startups receiving foreign funding
Expatriates and foreign employees