Tax Litigation
Income tax and GST disputes and GST audits handled from the first notice through assessment, appeal and stay of demand — with the record built to win.
Learn morePractice 07 · International Tax & Transfer Pricing
International tax and transfer pricing, documented to hold up
Transfer pricing study reports, benchmarking analyses and accountant’s reports for companies with cross-border group transactions — plus practical advice on tax treaties, withholding tax and permanent establishment.
Cross-border pricing you can defend
When an Indian company deals with its foreign parent, subsidiaries or other group entities, the tax department tests whether those prices are at arm’s length. Weak documentation is one of the most common reasons for large adjustments and long-running disputes.
We prepare transfer pricing studies and benchmarking reports built on a genuine functional analysis of your business, and advise on international tax questions such as treaty benefits and withholding tax. Because our tax litigation team defends the same files, we document with the assessment in mind.
Scope
What we handle
Transfer pricing
TP study report
Annual transfer pricing documentation: functional analysis of functions, assets and risks, characterisation of each entity, method selection and economic analysis — prepared to stand up in assessment.
Benchmarking reports
Comparable searches on recognised databases, documented screening and rejection of companies, and arm’s length range computation under Indian rules. Also standalone benchmarking when setting new intercompany prices.
Accountant’s report (Form 3CEB)
Preparing the report on international and specified domestic transactions, coordinated with the certifying chartered accountant and filed before the due date.
Intercompany pricing & agreements
Pricing policies for services, royalties, cost allocations, loans and guarantees, and intercompany agreements that match how the business actually operates.
Master file & CbCR
Master file filings and country-by-country reporting notifications and reports for multinational groups above the thresholds.
TP assessments, safe harbour & APAs
Defending TP audits before the Transfer Pricing Officer, Dispute Resolution Panel and ITAT with our tax litigation team, and evaluating safe harbour and Advance Pricing Agreements.
International tax
DTAA & treaty benefits
Treaty eligibility, Tax Residency Certificates, Form 10F and beneficial-ownership documentation to support reduced withholding rates.
Withholding tax on foreign payments
Tax deduction on payments to non-residents — royalties, fees for technical services, interest and dividends — and Form 15CA / 15CB for remittances.
Permanent establishment & inbound tax
PE risk reviews for foreign companies operating in India, and taxation of Indian branches, liaison and project offices.
Outbound & expatriate tax
Taxation of overseas subsidiaries and investments, foreign tax credits, and tax for expatriates and NRIs.
How we work
How we work
A disciplined path from first review to resolution — with one coordinated team.
Diagnose
We start with your documents, not assumptions — filings, financials, agreements and any notices.
Structure
A written plan with options, risks, costs and timelines, agreed with you before work begins.
Execute
Filings, submissions, documentation and negotiations handled by one coordinated team.
Sustain
Calendars, reviews and monitoring so issues are caught early — and defended if they arise.
FAQ
Transfer Pricing — common questions
Who needs a transfer pricing study report?
Indian entities that enter into international transactions with associated enterprises — and certain specified domestic transactions — must maintain transfer pricing documentation once the transactions exceed the prescribed threshold, and obtain an accountant’s report. We’ll confirm whether the requirements apply to you.
What is a benchmarking report?
A benchmarking report compares your intercompany prices or margins with those of independent comparable companies or transactions to show they are at arm’s length. It sets out the search process, the comparables accepted and rejected, and the resulting arm’s length range.
How often should the benchmarking be updated?
Comparable data should be refreshed every year using current financials, with a fresh search whenever the business model or transactions change. Relying on an outdated search is a common reason for adjustments.
When is the transfer pricing report due?
The accountant’s report must be filed before the due date of the income tax return — typically a month earlier — so the study should be ready well ahead. The Income-tax Act, 2025 applies from 1 April 2026 with renumbered provisions, and we track which forms and due dates apply to each year.
Can you defend a transfer pricing adjustment?
Yes. Our tax litigation team handles TP assessments before the Transfer Pricing Officer, objections before the Dispute Resolution Panel and appeals before the ITAT, using the documentation built during the study.
Related practices
Often engaged together
Talk to a senior advisor
Share your requirement and we’ll set out the options, timeline and fee before any work begins.