Transfer Pricing Services
Optimize cross-border transaction pricing, establish an ironclad arm’s length defence, and achieve complete multi-jurisdictional tax compliance with strategic transfer pricing advisory and documentation directed by practicing Chartered Accountants.
Transfer Pricing Services We Offer
Conducting database-driven economic analysis, and premium benchmarking searches to justify the arm’s length nature of international and domestic related-party transactions.
Compiling and maintaining the statutory three-tier record architecture—including Local Files, Master Files, and CbCR—mandated by global tax authorities.
Preparing comprehensive annual cross-border transaction audits, verifying multi-currency datasets, and certifying Form 3CEB filings on the Income Tax portal before statutory deadlines for compliance.
Defending your inter-company pricing methodologies and functional risk (FAR) profiles directly before Transfer Pricing Officers (TPOs) during routine tax audits and intense scrutiny hearings.
Structuring cross-border corporate channels, withholding tax (TDS) strategies, and treaty benefits to minimize multi-jurisdictional tax exposure.
Negotiating strategic, formal contracts with the CBDT to pre-determine arm’s length pricing metrics, permanently eliminating complex transfer pricing audit risks for up to 9 years.
Representing enterprises before appellate tribunals like the CIT(A) and ITAT to contest aggressive income adjustments and tax penalties.
Utilizing administrative safe zones notified by tax authorities to secure direct compliance relief and audit exemptions for eligible transactions.
Our Transfer Pricing Milestones Over the Years
135+
Companies
Incorporated
210+
ROC Filings Completed
128+
Director & Shareholder onboardings
98%
Success in
MCA Approvals
85+
Startups Assisted
Why Choose
B.K. Khemka & Co. ?
Comprehensive Transfer Pricing solutions handled by experienced Chartered Accountants
CA-Led Compliance
Entire registration is prepared & reviewed by qualified CAs, ensuring professional-grade accuracy.
Accuracy Guarantee
Our multi-level verification process ensures error-free filings, protecting you from notices and penalties.
Timely Filing & Reminders
Proactive deadline tracking and reminders ensure you never miss a due date. On-time, every time.
Dedicated Support
A dedicated compliance manager for all your queries, notices, and year-round TDS support needs.
Get Transparent Pricing for Transfer Pricing Services
No hidden charges. Clear pricing based on your needs.
Frequently Asked Questions
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What exactly is the “Tolerance Margin” or Arm’s Length Range in Indian Transfer Pricing?
The Indian tax framework allows a standard tolerance margin of ±3% (or ±1% in the case of wholesale trading) if the transaction pricing cannot be matched to a single point. For entities using multiple comparables under the Transactional Net Margin Method (TNMM), the law applies a dataset approach where the actual transaction price must fall between the 35th and 65th percentiles of the comparison pool to be accepted as arm’s length.
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What are Specified Domestic Transactions (SDT), and when do they apply?
Specified Domestic Transactions refer to certain related-party transactions within India that are brought under the transfer pricing framework to prevent tax evasion. They apply if the aggregate value of these transactions exceeds INR 200 million (INR 20 crores) in a financial year, and typically involve transactions with entities enjoying tax holidays (such as SEZ units) or businesses under common management with varying tax rates.
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What is a Secondary Adjustment under Section 92CE, and why is it highly penalized?
A secondary adjustment occurs when a primary transfer pricing audit results in an upward adjustment to your taxable income. The law requires that the excess profit allocated to India must be physically repatriated into the country within 90 days. If the funds are not brought back to India within this timeframe, the un-repatriated amount is treated as a deemed loan extended to the foreign entity, and interest income is imputed and taxed continuously until the cash arrives.
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What is an Advance Pricing Agreement (APA), and how does it benefit an MNC?
An Advance Pricing Agreement (APA) is a formal contract between a taxpayer and the Central Board of Direct Taxes (CBDT) that pre-determines the transfer pricing methodology and arm’s length pricing metrics for your international transactions over a fixed period. An APA provides complete tax certainty for up to 9 years (5 future years plus 4 rollback years), completely eliminating the risk of transfer pricing audits and prolonged legal disputes.
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What are the penalties for failing to maintain Transfer Pricing documentation or file Form 3CEB?
The penalties for transfer pricing non-compliance are severe. Failing to maintain the mandatory transfer pricing documentation or local file under Section 92D attracts a penalty of 2% of the total value of each international transaction. Additionally, failing to file the certified Form 3CEB before the statutory deadline results in a flat penalty of INR 1,00,000, alongside ongoing audit scrutiny.
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