Helping businesses manage cross-border tax, compliance, and transfer pricing with strategic precision and efficiency.
Our Transfer Pricing services support Indian and multinational corporations in developing and implementing robust, economically sound transfer pricing policies and documentation. We offer comprehensive strategies to manage complex transfer pricing issues arising from inter-company transactions involving goods, services, and intangibles. Our services include Transfer Pricing Compliance with Three-Tier Documentation, Transfer Pricing Planning and Supply Chain Restructuring, and Litigation Support for managing transfer pricing disputes. We assist with Advance Pricing Arrangements (APA), Mutual Agreement Procedures (MAP), Form 3CEB, Form 3CEAA (Part A and B), Form 3CEAB, Master Filings, TP Documentation, TP Study,PE study, Profit attribution analysis, Advance rulings etc. and Transfer Pricing Valuation Services. We also help realign existing transfer pricing documentation in line with BEPS requirements.
At PGAS & Associates, we provide end-to-end support to ensure full compliance with the Indian Transfer Pricing (TP) regulations under the Income Tax Act, 1961 and the OECD Guidelines. Our professionals combine technical excellence with practical experience across industries to help multinational groups manage transfer pricing risks effectively.
| Scope of Work | Key Deliverables |
| Reviewing transfer pricing positions and international transactions | Detailed analysis of related party transactions (RPTs), FAR profiling, and intercompany agreements. |
| Analyzing group structure and industry | Understanding global value chain and business models to identify TP exposures and defendable policies. |
| Determining the most appropriate method | Evaluating TNMM, CUP, CPM, RPM, or PSM to establish the arm’s length principle as per Rule 10B. |
| Economic & financial benchmarking | Conducting database searches to identify comparables, compute profit level indicators, and determine ALP ranges. |
| Pricing analysis | For tangible goods, intangibles, intercompany services, and financing arrangements (loans, guarantees, etc.). |
| Transfer Pricing Documentation (Local File & Master File) | Preparation of 3-tier documentation in line with BEPS Action 13 and Indian regulations. |
| Accountant’s Report – Form 3CEB | Issuance of Form 3CEB in compliance with Section 92E of the Income Tax Act. |
Transfer Pricing planning aligns business and pricing models to reduce risk and tax costs, while supply chain structuring minimizes compliance expenses and penalties. We assist in policy development, harmonization, and adjustments to business changes.
Our Transfer Pricing planning and supply chain structuring services include the following:
Our controversy management services focus on helping clients develop strategic responses to tax disputes. We collaborate with you to devise strategies and practices for handling audit and appeal proceedings, whether before the Transfer Pricing Officer (TPO), Dispute Resolution Panel (DRP), Commissioner of Income Tax (Appeal), Income Tax Appellate Tribunal (ITAT), or High Court (HC).
The Advance Pricing Agreement (APA) mechanism, introduced by the Finance Act, 2012, ensures certainty in transfer pricing by agreeing on the Arm’s Length Price (ALP) for future international transactions. With rollback provisions, the APA covers prior years, offering tax certainty for up to nine years. We assist clients through every step, from consultations and documentation to negotiations and post-agreement compliance, ensuring a smooth process with the CBDT and tax authorities.
The Mutual Agreement Procedure (MAP) is a key tool for resolving double taxation and cross-border transfer pricing disputes. India’s network of 70+ Double Taxation Avoidance Agreements (DTAAs) allows competent authorities to negotiate and eliminate double taxation. Our team supports clients throughout the MAP process, from drafting position papers and coordinating with authorities to ensuring the final resolution is implemented, protecting profits and maintaining global tax certainty for multinational enterprises.
Under FIN 48 (Accounting for Uncertain Tax Positions), companies must identify and disclose uncertain tax or transfer pricing positions reflected in their financial statements. Our professionals assist in evaluating potential exposures, quantifying risks, and preparing detailed analyses consistent with audit requirements and disclosure norms. Through this service, we enable clients to evaluate their tax positions with clarity, ensuring both regulatory compliance and transparency in financial reporting.
Restructuring business operations, transferring intangibles, or reorganizing investments often requires a clear understanding of valuation implications under transfer pricing and tax regulations. We perform independent valuations of shares, businesses, and intangible assets to ensure transactions are consistent with arm’s length principles and compliant with both FEMA and Income Tax laws. Our experts integrate financial modeling with transfer pricing methodologies to deliver robust, defensible valuations aligned with international standards.
The three-tier documentation enhances transparency for tax authorities, making deviations from transfer pricing policies more evident globally. Multinational Enterprises (MNEs) must assess existing data and inconsistencies to ensure compliance. We help align Transfer Pricing models with BEPS Action 13 standards to mitigate risks and tax costs.
