Comprehensive TP documentation, benchmarking, Master File / Local File preparation, and BEPS compliance for related-party transactions across borders.
Transfer Pricing governs the pricing of goods, services, and intangibles traded between related entities. Indian TP regulations (Sections 92A-92F) require that such transactions be at arm's length, supported by comprehensive documentation.
TP adjustments by the Indian tax authorities can increase taxable income by 10-30% and attract penal interest. With the introduction of BEPS Action 13 (Master File / Local File / CbCR), documentation requirements have become significantly more stringent.
SilverSiX provides end-to-end TP support — from functional analysis and benchmarking to APA applications and dispute resolution.
Comprehensive functional, risk, and asset analysis with comparable company search and arm's length range determination.
Preparation of BEPS Action 13 compliant documentation for Indian and global reporting.
Country-by-Country Reporting and BEPS Action Plan compliance for MNE groups.
Advance Pricing Agreement applications for certainty on future related-party transactions.
Valuation and pricing of intellectual property, royalties, and technology transfers.
Representation before Transfer Pricing Officers and Appellate authorities.
We identify all related-party transactions (goods, services, intangibles, financial) and classify them by nature and value.
Detailed functional, risk, and asset analysis of each entity to determine the most appropriate TP method.
Comparable company search using databases (Prowess, Capitaline, Orbis) and application of appropriate filters.
Preparation of Accountant's Report (Form 3CEB), Master File, Local File, and CbCR (if applicable).
Recommendations for TP policy changes, cost allocation, and safe harbour opportunities.
Representation before TPO, DRP, and ITAT. MAP and APA support where applicable.
| Deliverable | Description | Timeline |
|---|---|---|
| TP Policy Document | Group-level transfer pricing policy & methodology | Week 2 |
| FAR Analysis | Functional, risk & asset profile of each entity | Week 3 |
| Benchmarking Report | Comparable search, filters & arm's length range | Week 4–6 |
| Form 3CEB | Accountant's report for related-party transactions | October 31 |
| Master File | BEPS Action 13 compliant group documentation | November 30 |
| Local File | Entity-level transaction documentation | November 30 |
| CbCR | Country-by-Country Report (XML + form) | November 30 |
| APA Application | Draft APA submission to CBDT (if elected) | Per engagement |
Book a confidential discovery call with our advisory team. We assess your situation and outline a clear execution roadmap within 48 hours.
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