Related-party pricing is a top scrutiny area for Indian tax authorities. PJRJ provides transfer pricing studies, benchmarking, documentation, and defence strategies aligned with Indian rules and OECD guidance.
Transfer pricing services
TP study & benchmarking
Comparable analysis for goods, services, royalties, and intra-group financing.
Documentation support
Master file and local file elements, FAR analysis, and economic ownership mapping.
APA & safe harbour advisory
Advance Pricing Agreement strategy and safe harbour eligibility assessment.
Audit & litigation defence
Supporting documentation for TP audits and appellate proceedings.
Who it's for
- Indian companies making foreign investments or receiving overseas income
- Foreign subsidiaries and JV partners entering the Indian market
- Businesses with related-party imports, royalties, or management fees
- Groups requiring transfer pricing documentation and benchmarking support
Deliverables
- Transaction tax structuring memo — Indian and treaty implications
- Withholding tax analysis and Form 15CA/CB support
- Transfer pricing study, benchmarking, and documentation (Master/Local file elements)
- Advance ruling or APA advisory where appropriate
- FEMA reporting coordination with RBI compliance requirements
Our approach
- 1Map transaction flow — parties, functions, risks, and substance
- 2Analyse Income-tax Act, 2025 provisions and applicable DTAA articles
- 3Recommend structure balancing tax efficiency and regulatory acceptance
- 4Document contemporaneously for audit and TP defence
- 5Coordinate with legal counsel on agreements and regulatory filings
Delhi NCR groups paying UAE/UK/Singapore related parties for “management fees” or goods need a FAR that matches the contract and the 15CA characterisation. A benchmarking report that ignores customs values or GST invoices will not survive a TP officer who has both. Safe harbour and APA are optional tracks we assess — we do not sell them as a default product.
Discuss your transfer pricing requirements
Speak directly with a PJRJ specialist — we respond within one business day.