Transfer Pricing in India


At Numbersmiths Consulting, we offer comprehensive transfer pricing services to help businesses navigate the complexities of transfer pricing regulations in India. Our package includes a range of services designed to ensure compliance with transfer pricing regulations and optimize your international transactions. Here’s an overview of our Transfer Pricing services:

At Numbersmiths Consulting, we provide comprehensive domestic transfer pricing services to help businesses comply with Indian tax regulations and optimize their intra-group transactions. Our package includes a range of services designed to ensure compliance and mitigate transfer pricing risks.

Our Transfer Pricing in India include:

Transfer Pricing Support Advisory

Our experienced team provides expert advisory services to assist you in understanding and complying with transfer pricing regulations. We analyze your business transactions, identify potential transfer pricing risks, and provide strategic guidance to mitigate those risks.

Transfer Pricing Services in Compliance with Regulations

We assist businesses in aligning their transfer pricing practices with Indian regulations. Our experts help you determine the appropriate transfer pricing methodologies, benchmark comparable transactions, and ensure compliance with documentation requirements.

Compliance Review – Monthly/Quarterly & Annually

We offer regular compliance reviews to ensure ongoing adherence to transfer pricing regulations. Our team conducts comprehensive reviews of your financial and operational data to identify any potential transfer pricing issues and provide recommendations for remediation.

Transfer Pricing Documentation

We help businesses prepare robust transfer pricing documentation that meets the requirements of Indian tax authorities. Our experts assist in gathering relevant financial and operational data, performing benchmarking analysis, and preparing comprehensive transfer pricing documentation reports.

Transfer Pricing Audit

In the event of a transfer pricing audit, our team provides assistance and representation throughout the audit process. We work closely with tax authorities to address their queries, provide supporting documentation, and advocate for your position to ensure a fair and favorable outcome.

Assistance in Preparation & Filing of Master File & CBC Report

We guide businesses in preparing and filing the Master File and Country-by-Country (CBC) report as per Indian transfer pricing regulations. Our experts ensure accurate and timely submission of these reports to meet compliance requirements.

Assisting Clients in Understanding & Implementing Safe Harbor Rules

We provide guidance on safe harbor rules and assist businesses in implementing safe harbor methodologies to simplify transfer pricing compliance and reduce the risk of transfer pricing adjustments.

At Numbersmiths Consulting, we understand the challenges businesses face in managing transfer pricing in India. Our dedicated team of transfer pricing experts is well-versed in Indian regulations and international best practices. We work closely with clients to ensure compliance, optimize transfer pricing structures, and mitigate transfer pricing risks.


Our transfer pricing services are designed to help businesses establish and maintain arm’s length pricing for their international transactions. We provide expert advice, documentation support, compliance reviews, and assistance in transfer pricing audits.

Domestic transfer pricing refers to the pricing of transactions between related entities within India. It aims to ensure that these transactions are conducted on an arm’s length basis, similar to international transfer pricing. It involves determining the appropriate pricing for various intra-group transactions, such as the sale of goods, provision of services, or transfer of intangible assets.

Importance of Transfer Pricing:

Transfer pricing plays a crucial role in determining taxable profits, ensuring fairness in taxation, and preventing base erosion and profit shifting. It helps businesses align their pricing with market conditions and international standards, ensuring compliance with Indian transfer pricing regulations.

Benefits of Domestic Transfer Pricing

  • Compliance: By adhering to domestic transfer pricing regulations, businesses can ensure compliance with Indian tax laws and regulations, minimizing the risk of penalties, disputes, and additional tax assessments.
  • Risk Mitigation: Implementing robust domestic transfer pricing policies and documentation helps mitigate transfer pricing risks and ensures that intra-group transactions are conducted at arm’s length, reducing the likelihood of tax authority challenges.
  • Efficient Tax Planning: Properly structuring intra-group transactions allows businesses to optimize their tax positions and allocate profits appropriately, enhancing overall tax planning strategies.

Threshold Limit for Domestic Transfer Pricing

As per Indian tax regulations, the requirement to maintain and furnish domestic transfer pricing documentation applies to businesses whose total value of specified domestic transactions exceeds INR 20 crores during the financial year. Specified domestic transactions include the purchase, sale, or lease of tangible assets, provision of services, borrowing or lending of money, or any other transaction as notified by the tax authorities.

Methods of Domestic Transfer Pricing

The Income Tax Act in India provides various methods for determining an arm’s length price for domestic transfer pricing purposes. These methods include the Comparable Uncontrolled Price (CUP) method, Resale Price Method (RPM), Cost Plus Method (CPM), Transactional Net Margin Method (TNMM), and Profit Split Method (PSM). The selection of the most appropriate method depends on the nature of the transaction and the availability of comparable data.

At Numbersmiths Consulting, we have a team of experienced transfer pricing professionals who specialize in domestic transfer pricing. We stay updated with the latest developments in Indian tax regulations and transfer pricing guidelines, ensuring that our clients receive accurate and reliable advice. Our experts will work closely with your business to develop customized transfer pricing solutions that comply with Indian tax laws and optimize your intra-group transactions.

Methods of Transfer Pricing:

In transfer pricing, different methods are used to determine the appropriate pricing for transactions between related entities. The selection of the method depends on the nature of the transaction, availability of data, and the level of comparability. Here are some commonly used transfer pricing methods:

  • Comparable Uncontrolled Price (CUP) Method: This method compares the price of the controlled transaction with the price of a similar transaction between unrelated parties. It is considered the most direct and reliable method when there are comparable uncontrolled transactions available.
  • Resale Price Method (RPM): The RPM focuses on the gross margin earned by the reseller. It compares the resale price of goods purchased from a related party with the resale prices of similar goods in transactions between unrelated parties.
  • Cost Plus Method (CPM): The CPM determines the arm’s length price by adding an appropriate markup to the costs incurred by the supplier of goods or services. The markup should be consistent with the industry norm for similar functions.
  • Transactional Net Margin Method (TNMM): The TNMM compares the net profit margin earned from a controlled transaction with the net profit margin realized in similar transactions between unrelated parties. It takes into account the profitability of the entity relative to an appropriate base such as sales, assets, or costs.
  • Profit Split Method: This method allocates the combined profits of related entities based on the relative value they contribute to the overall transaction. It is commonly used for transactions involving the joint development of intangibles or unique contributions from each party.
  • Transactional Profit Split Method: Similar to the profit split method, the transactional profit split method allocates profits based on the relative value of each party’s contribution to specific transactions.

At Numbersmiths Consulting, we have extensive experience in applying these transfer pricing methods and selecting the most appropriate method for your specific transactions. Our team of transfer pricing experts ensures that your transfer pricing practices are in line with Indian regulations and international best practices, minimizing the risk of disputes and ensuring compliance.

Why Choose Numbersmiths Consulting for Transfer Pricing in India Services?


Our team consists of highly experienced transfer pricing professionals who have in-depth knowledge of Indian transfer pricing regulations and international best practices.

Tailored Solutions

We understand that each business is unique, and we provide customized transfer pricing solutions that align with your specific needs and objectives.

Compliance Assurance

We ensure that your transfer pricing practices are in compliance with Indian regulations, minimizing the risk of penalties, disputes, and reputational damage.

Holistic Approach

Our services encompass the entire transfer pricing lifecycle, from advisory and documentation to compliance reviews and audit support, providing you with comprehensive support at every stage.

Client-Centric Approach

We prioritize building long-term relationships with our clients and strive to deliver exceptional service by understanding your business, addressing your concerns, and providing proactive advice and solutions.


1. What is transfer pricing?
Transfer pricing refers to the pricing of transactions between related entities, such as subsidiaries of the same multinational company, located in different tax jurisdictions. It involves determining the appropriate pricing for these transactions to ensure they are conducted on an arm’s length basis.
2. Why is transfer pricing important?
Transfer pricing is important because it affects the allocation of profits and taxes between different tax jurisdictions. It helps prevent profit shifting and ensures that profits are allocated fairly based on the value contributed by each entity involved in the transaction.
3. What are the risks of non-compliance with transfer pricing regulations?
Non-compliance with transfer pricing regulations can lead to tax disputes, penalties, and additional tax assessments by tax authorities. It can also damage a company’s reputation and erode stakeholder trust.
4. What documentation is required for transfer pricing compliance?
Transfer pricing documentation typically includes a master file, local file, and country-by-country reporting (CBCR). The master file provides an overview of the multinational group’s global business operations, while the local file contains detailed information about specific intercompany transactions. CBCR is a high-level report providing information on the global allocation of income, taxes paid, and other economic indicators.
5. What is an Advance Pricing Agreement (APA)?
An Advance Pricing Agreement (APA) is a pre-approval arrangement between a taxpayer and tax authorities regarding the pricing of future intercompany transactions. APAs provide certainty and reduce the risk of transfer pricing disputes by agreeing on an acceptable transfer pricing methodology in advance.
6. Why should I choose Numbersmiths Consulting for transfer pricing services?
At Numbersmiths Consulting, we have a team of experienced transfer pricing experts who are well-versed in Indian transfer pricing regulations and international best practices. We provide comprehensive transfer pricing services tailored to your specific business needs, ensuring compliance and minimizing transfer pricing risks.
7. How can I get started with Numbersmiths Consulting for transfer pricing services?
To get started with our transfer pricing services, simply reach out to our team via phone or email. We will schedule an initial consultation to understand your business requirements and develop a customized solution for your transfer pricing needs.

Contact us to learn more about our Transfer Pricing services and optimizing your international transactions.