From Pricing to Defense - Transfer Pricing for the Indian Landscape
We align inter-company pricing with business substance, benchmark outcomes to market reality and support documentation and dispute readiness so you can transact with confidence and defend value creation.
In today’s global and inter-connected business environment, companies must navigate a complex transfer-pricing landscape where regulatory expectations, value-chain dynamics and documentation burdens converge. Many businesses struggle with aligning commercial operations with pricing positions that are defensible under India’s evolving jurisprudence, while simultaneously meeting statutory mandates and managing audit exposure. At KCM, we are well equipped to operate at the vital intersection of business reality, regulatory expectation and practical interpretation. Our work focuses on articulating how value is created, how risks are managed, and how pricing reflects the commercial role of the Indian entity within the group. We have a wide experience in handling various cross-border transactions of tangibles, intangibles, and services and inbound and outbound investments.
With 20+ years in Indian TP engagements, we blend deep industry insight with legal and economic rigour to interpret value chains, pricing outcomes and regulatory expectations.
Having served varied industries ranging from manufacturing to startups, our breadth of experience allows us a strategic vantage point to advise our clients with the best approaches.
While technical accuracy is our foundation, we always emphasise an explainable economic rationale aligned with your business operations and strategic group role – not just a compliant formality.
Services Offered
Pricing & Policy Alignment
We help you design and evaluate inter-company pricing arrangements – aligning global frameworks with Indian realities. Our support includes:
- Evaluation and understanding of the global requirement
- Aligning expectations including cost base, markup requirements, invoicing methodologies and credit terms
- Bridging the gap between global and Indian approach
- Pricing of goods and component flows
- Technical and managerial support arrangements
- Royalty and technology-use frameworks
Financial support and guarantee fee models
Benchmarking & Documentation
We assist companies in formally preparing a documentation that sets out the business framework, functional profile, and economic comparability in a clear and defensible manner. Documentation support includes:
- Functional, asset and risk analysis aligned with actual decision-making roles
- Comparable selection based on commercial comparability, not mechanical filters
- Local File documentation under Rule 10D
- Form 3CEB preparation and review
- Master File support under Rule 10DA, where applicable
- CbCR support under Rule 10DB, where applicable
Assessment Support & Dispute Management
We assist clients during transfer pricing assessments and at appellate forums, focusing on consistency in narrative and evidence. Our support includes:
- Response strategy and submissions to the Transfer Pricing Officer
- Economic counter-analysis to adjustments
- Representation before TPO, DRP, and ITAT
- Counsel briefing and litigation coordination for matters before High Courts and Supreme Court
Safe Harbour, APA & MAP Services
Having a dynamic tax office and revenue approach has taught us to approach certainty before defence. We advise on mechanisms that provide certainty and alignment across jurisdictions. Services include:
- Evaluation of Safe Harbour applicability
- Preparation and negotiation of Unilateral and Bilateral APAs
- MAP representation to address or prevent double taxation
We manage the technical, procedural and presentation aspects of these processes end-to-end.
From Principle to Practice - achieving the arm’s length outcome
We design and implement global transfer-pricing frameworks that align value creation, pricing outcomes and documentation – enabling multinational groups to navigate cross-border risk and transact with certainty.
Multinational enterprises today face a complex transfer-pricing environment: evolving business models, shifting supply chains, heightened enforcement under Organisation for Economic Co‑operation and Development (OECD) BEPS frameworks, and divergent local tax-jurisdiction expectations. Without a coherent global strategy, you risk inconsistent pricing policies, documentation gaps, disputes and value-erosion. We help you build transfer-pricing policy, value-chain alignment, documentation and dispute-prevention tools that function as a unified global narrative. We evaluate transfer pricing in the context of the industry’s commercial, operational and regulatory characteristics, rather than applying uniform benchmarking frameworks.
With multi-jurisdictional depth and local insight, we deliver integrated transfer-pricing solutions that hold up in any market and under any scrutiny.
Leveraging expansive cross-border experience across 20+ geographies, our work combines industry specific value chain mapping, jurisdiction-level responsibility, decision-rights analysis and assessment of where economic contribution and enhancement actually occur.
Services Offered
Global Transfer Pricing Policy & Value Chain Alignment
We assist groups in defining transfer pricing policies that reflect the economic contribution of each entity across the value chain. This includes:
- Mapping functions, assets and risks across operating jurisdictions
- Identifying principal entities, routine units, captive units and shared service centres
- Aligning pricing outcomes with ownership and management of key risks and intangibles
- Documenting group-wide pricing policy frameworks for internal adoption
Operating Model Design and Restructuring
Be it mergers or acquisitions, business model restructurings or simply a change in functional profile, our team helps evaluate the need for change in transfer pricing policies and document both the evaluation & result for future use. We support:
- Transition between entrepreneurial entities and routine service or distribution models
- Establishment of principal structures, global hubs, and IP-owning entities
- Offshore-onshore role delineation and shared delivery centre integration
- Pricing realignment due to changes in supply chain, customer geography or technology development models
Global Benchmarking and Documentation Coordination
We provide support for local file, master file, and CbCR requirements across jurisdictions, ensuring a coherent narrative at group and entity levels. We work alongside local advisors where required to maintain jurisdictional alignment. Our support includes:
- Preparation / review of Master File
- Coordination of Local File documentation across multiple countries
- Cost optimization through centralized benchmarking for royalty, services, manufacturing, distribution and financing
- Ensuring consistency in functional analysis, comparability logic and pricing conclusions across entities
Intercompany Services, Royalty and Intangible Arrangements
We assist in designing and documenting intra-group service and intangible frameworks, ensuring clarity on:
- Service qualification and benefit analysis for intra-group support functions
- Royalty and technology-use arrangements aligned with DEMPE responsibilities
- Intra-group financing and guarantee fee models linked to the nature of support and risk assumption
- Allocation of shared platform, infrastructure and global support costs using consistent, defensible allocation keys
Dispute Prevention and Pricing Certainty (Selective Support)
Where appropriate, we can support:
- Mutual Agreement Procedure (MAP) coordination
- Group-wide policy articulation to minimise disputes
- Advance Pricing Agreements (APA) at bilateral / multilateral levels
Our focus here is policy clarity and documentation, rather than litigation.