Practice Areas · Compliance · Taxation & Advisory · Direct & international tax · Transfer pricing
Transfer Pricing Advisory
Arm's-length pricing of related-party transactions, with the documentation and reporting the law requires.
What transfer pricing covers
Transfer pricing governs the pricing of transactions between related parties so that profits are not artificially shifted across jurisdictions. Indian law requires such transactions to be at arm's length, supported by a documented study, and reported.
The firm benchmarks related-party transactions, prepares the documentation, certifies Form 3CEB, and advises on the master file and country-by-country reporting where they apply.
What we deliver
Transfer-pricing work covers the analysis, documentation, and reporting, including:
- Identifying international and specified domestic related-party transactions
- Functional, asset, and risk (FAR) analysis and method selection
- Benchmarking against comparables to establish the arm's-length range
- The transfer-pricing study and Form 3CEB certification
- Master file (3CEAA) and CbCR (3CEAD) where thresholds are met
How we work
- 01
Identify transactions
Map the related-party transactions in scope.
- 02
Analyse & benchmark
Run the FAR analysis, select the method, and benchmark comparables.
- 03
Document & certify
Prepare the study and certify Form 3CEB.
- 04
Support filings & defence
File master file/CbCR where due and support any assessment.
Why work with PBT
PBT keeps your related-party pricing defensible and your reporting complete.
- Robust benchmarking and method selection
- Documentation that supports the arm's-length position
- Timely Form 3CEB certification
- Master-file and CbCR compliance where applicable
- Scope, deliverables, and fees agreed in writing up front
Frequently asked questions
Who needs transfer-pricing documentation?
Any taxpayer with international related-party transactions, and specified domestic transactions above the threshold, must maintain documentation and file Form 3CEB.
What is Form 3CEB?
A CA's report certifying the related-party transactions and the arm's-length analysis, filed with the income-tax department.
How long does it take?
A study with benchmarking typically takes a few weeks; we plan it to the Form 3CEB due date.
Get transfer pricing right
Tell us about your related-party transactions, and we'll benchmark, document, and certify them.
Send an enquiryThis page describes the nature of the firm's services and is not a solicitation or legal advice. Thresholds, timelines, and applicable registrations depend on your specific facts; engagement terms and fees are agreed in writing per assignment.