CORPORATE • REGULATORY • LEGAL • BUSINESS ADVISORY
Transfer Pricing Coordination advisory and legal support
INTERNATIONAL TAX · TAXATION & COMPLIANCE

Transfer Pricing Coordination

Align Intercompany Transactions with Arm's-Length Principles, International Tax Standards and Regulatory Confidence.

TRANSFER PRICING COORDINATION

Understanding Transfer Pricing Coordination in India

Astronis Global provides integrated legal, regulatory and tax coordination for transfer pricing matters, helping multinational groups and Indian businesses manage related-party transactions, documentation, benchmarking, statutory compliance and disputes.

Transfer pricing requires a clear picture of related-party transactions, functions, assets, risks and supporting evidence. Coordinate policy, documentation and reporting with the business model and current rules.

OUR SERVICES FOR TRANSFER PRICING COORDINATION

Our transfer pricing coordination services

Coordinated transfer pricing coordination support shaped around your business context and applicable requirements.

Associated Enterprise Transaction Assessment

Identify related-party relationships and covered international or specified domestic transactions.

Arm's-Length Pricing & Benchmarking Coordination

Coordinate pricing methods, comparable data and economic analyses.

Functional, Asset & Risk Analysis

Evaluate functions performed, assets used, risks assumed and business context.

Intercompany Agreements & Transaction Structuring

Review and document service, financing, licensing and distribution arrangements.

Transfer Pricing Documentation & Compliance

Coordinate local files, master files, Form 3CEB and other statutory requirements.

Transfer Pricing Disputes, APA & MAP Coordination

Support dispute resolution, advance pricing and mutual agreement processes.

KEY BENEFITS

Why transfer pricing coordination matters

Transfer pricing requires a clear picture of related-party transactions, functions, assets, risks and supporting evidence. Coordinate policy, documentation and reporting with the business model and current rules.

Transfer Pricing Coordination advisory and legal support
Transfer Pricing Coordination
Considered for your next chapter.

Demonstrate a defensible…

Demonstrate a defensible arm's-length approach.

Meet regulatory and…

Meet regulatory and documentation requirements.

Identify alignment gaps in…

Identify alignment gaps in related-party transactions.

Support global business expansion

Support global business expansion.

Improve transaction management…

Improve transaction management and certainty.

Prepare for review, audit and…

Prepare for review, audit and dispute resolution.

REGULATORY FRAMEWORK

Legal framework for transfer pricing coordination

Transfer pricing requires a clear picture of related-party transactions, functions, assets, risks and supporting evidence. Coordinate policy, documentation and reporting with the business model and current rules.

  • Income-tax Act, 1961 — Sections 92–92F

    Transfer pricing provisions for international and specified domestic transactions.

  • Income-tax Rules, 1962 — Rules 10A–10TH

    Methods, documentation and procedural requirements.

  • Form 3CEB & accountant reporting

    Reporting obligations depend on transaction applicability.

  • OECD Transfer Pricing Guidelines

    International reference material where relevant to analysis.

  • APA, MAP & dispute provisions

    Advance pricing and mutual agreement processes where available.

Transfer Pricing Coordination advisory and legal support
Structure for today.
Clarity for what comes next.
COMPARATIVE ANALYSIS

Transfer pricing methods at a glance

A practical overview of transfer pricing coordination considerations. The appropriate route depends on the facts, applicable law and current requirements.

FeaturesMethodCore principleTypical application
Comparable Uncontrolled PriceCompare price with comparable independent dealingsCommodities and comparable products
Resale Price MethodDeduct an appropriate resale marginDistribution and resale activities
Cost Plus MethodApply an appropriate mark-up to costsManufacturing and service providers
Transactional Net Margin MethodCompare net profit indicatorsWhere direct price comparisons are limited
Profit Split MethodAllocate combined profits by contributionHighly integrated or unique contributions

Use this overview as a starting point for advice on the proposed structure and circumstances.

TRANSFER PRICING COORDINATION PROCESS

Transfer pricing coordination process

A clear sequence of decisions and filings, coordinated around complete information and authority processing.

  1. Transaction mapping

    Identify associated enterprises, transaction types and values.

  2. Document collection

    Gather agreements, financial data and supporting records.

  3. Functional analysis

    Analyse functions performed, assets used and risks assumed.

  4. Methodology & benchmarking

    Select and support the most appropriate method and comparables.

  5. Documentation & reporting

    Prepare or coordinate required files and statutory reports.

  6. Implementation support

    Align intercompany agreements, invoices and operating practice.

  7. Ongoing monitoring

    Review changes and maintain evidence for audit or dispute.

DOCUMENTS & REQUIREMENTS

Documents for transfer pricing coordination

The exact checklist depends on the matter, available records and applicable procedure.

  • Group structure and associated-enterprise details
  • Intercompany agreements and transaction summaries
  • Segmented financial data and accounting records
  • Functional, asset and risk information
  • Benchmarking data and prior transfer pricing studies
  • Form 3CEB, local file, master file and tax authority correspondence
PROFESSIONAL FEES & ADVISORY PACKAGES

Transfer Pricing Coordination professional fees

Fees depend on the matter, complexity, urgency, jurisdictions and agreed scope.

INITIAL ASSESSMENT

Transfer Pricing Coordination assessment

On request
  • Initial matter and document review
  • Applicable requirement assessment
  • Recommended next steps
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EXTENDED SUPPORT

Transfer Pricing Coordination support

On request
  • Matter-specific planning
  • Filing or representation coordination
  • Ongoing status and deadline support
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FOR COMPLEX REQUIREMENTS

Complex or connected requirements

Request a tailored scope for complex matters or connected workstreams related to transfer pricing coordination.

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Government fees, court charges and third-party costs are confirmed separately against current requirements.

KEY FEATURES

Transfer Pricing Coordination at a glance

Demonstrate a defensible arm's-length approach.
Meet regulatory and documentation requirements.
Identify alignment gaps in related-party transactions.
Support global business expansion.
Improve transaction management and certainty.
Prepare for review, audit and dispute resolution.
FREQUENTLY ASKED QUESTIONS

A few useful answers

Common questions about transfer pricing coordination and the relevant process.

Browse all FAQs
What is transfer pricing?
What is the arm's-length principle?
Which transfer pricing method should be used?
What is Form 3CEB?
Can an APA provide certainty?
TESTIMONIALS

Clear advice. Practical direction.

Perspectives shared with permission by clients of our advisory teams.

Astronis Global brought clarity and commercial focus to a complex restructuring exercise. Their advice was practical, timely and easy for our leadership team to act on.
Ananya MehtaChief Executive Officer, Northstar Manufacturing Pvt. Ltd.★★★★★
The team understood our regulatory requirements quickly and helped us move forward with confidence. We valued their responsiveness and disciplined follow-through.
Rohan KapoorFounder & Managing Director, Vertex Digital Solutions★★★★
Astronis Global provided dependable support across multiple registrations and approvals. Their communication was clear, structured and consistently professional.
Priya NairGeneral Counsel, Meridian Healthcare Group★★★★★
YOUR NEXT CHAPTER STARTS HERE

Strengthen global operations with robust transfer pricing coordination

Coordinate related-party transaction analysis, documentation, benchmarking and dispute support.

Request Transfer Pricing Advisory