Transfer pricing advisory involves setting, documenting, and defending the pricing of transactions between related business entities—whether across borders or within India. These include services, goods, loans, royalties, or management fees shared between group companies.
Indian regulations (Sections 92–92F of the Income Tax Act) and global standards (OECD BEPS) require such transactions to follow the “arm’s length principle.” MMG Consulting helps businesses maintain transfer pricing compliance, avoid disputes, and design effective intercompany pricing strategies.
Preparation of compliant documentation for Indian and global requirements under Sections 92D and Rule 10D, including FAR (Functions, Assets & Risks) analysis.
Conducting economic analysis and benchmarking using appropriate databases (Prowess, Capitaline) and selecting the most suitable pricing method.
Developing intercompany pricing strategies that are tax-efficient and defendable during audits.
Assistance with unilateral, bilateral, or multilateral APA applications with Indian tax authorities for long-term certainty.
CbCR filings under BEPS Action Plan 13 for multinational groups, including preparation and submission of Form 3CEAC, 3CEAD, and 3CEAE.
Arm’s length evaluation of management fees, shared services, royalty, and license fees with robust documentation.
Support during transfer pricing assessments, documentation reviews, and representation before tax authorities or appellate bodies.
Identify and classify all international and specified domestic transactions within the group.
Conduct Functions, Assets, and Risk analysis to determine each entity’s role and contribution.
Select the most appropriate method (e.g., CUP, TNMM, Cost Plus) and conduct benchmarking analysis.
Draft local file, master file, and CBC reports in line with Indian and OECD guidelines.
File forms (3CEB, 3CEAA, 3CEAD, etc.) and provide year-round guidance for audits, APA, or policy revisions.
Our team includes CA professionals with in-depth knowledge of Indian TP law, OECD guidelines, and global structuring norms.
We offer tailored TP strategies for tech, pharma, manufacturing, and service sectors, aligning with practical business models.
From planning and benchmarking to documentation, filing, and audit defense—we manage the full lifecycle of your TP compliance.
We’ve supported multiple APA applications, Form 3CEB certifications, and client audits with consistent success.
Our advisory bridges Indian compliance with global group policies—ensuring consistency across jurisdictions.
Proper documentation and pricing strategies reduce the risk of income adjustments and penalties under Section 271AA, 271BA, and 270A.
Our reports are prepared to withstand scrutiny from Indian tax authorities and global regulatory bodies.
We ensure your global transfer pricing strategy aligns with OECD and Indian frameworks.
Design pricing models that optimize tax impact while complying with regulations.
We assist during transfer pricing audits, DRP proceedings, or ITAT litigation when required.
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India’s payroll landscape has grown increasingly complex. Organizations must manage Provident Fund (PF), Employee State Insurance (ESI), Professional Tax, TDS…
Transfer pricing refers to the pricing of goods, services, or intangibles between related entities. It ensures transactions reflect market value, preventing tax base erosion.
Any company entering into international or specified domestic transactions with associated enterprises must file Form 3CEB, certified by a CA.
Non-compliance can attract penalties of up to 2% of the transaction value, disallowance of expenses, and increased scrutiny.
Yes, we prepare local and master files as per Indian and global requirements and coordinate with your group tax teams.
Annually. Every assessment year requires a fresh set of documentation reflecting that year’s transactions and economic analysis.
As an accounting firm, we take pride in being able to assist other companies providing trusted accounting support.
