Trusted Transfer Pricing Advisors for Indian Corporates & Multinationals

Transfer Pricing Services in India

Cross border transactions between associated enterprises demand rigorous pricing discipline and airtight documentation. RVG Consulting Private Limited provides structured, regulation aligned Transfer Pricing Services helping Indian corporates, multinational enterprises, and foreign subsidiaries manage intercompany transactions with full statutory compliance.

Mandatory under Sections 92–92F, Income Tax Act, 1961

Why Transfer Pricing Compliance Cannot Be Overlooked

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Every international transaction between associated enterprises must reflect an arm's length price under Indian law. Non compliance carries penalties of up to 2% of transaction value, prolonged assessments, and significant reputational risk. Robust Transfer Pricing documentation is not merely a statutory obligation it is your primary defence before tax authorities.

Under Indian law, Transfer Pricing documentation is mandatory where international transactions exceed ₹1 crore, and specified domestic transactions exceed ₹20 crore. Form 3CEB must be filed annually by a Chartered Accountant. Non maintenance of documentation alone attracts a penalty of 2% of transaction value making proactive compliance significantly more cost effective than reactive dispute management.

RVG Consulting Private Limited provides Transfer Pricing compliance and advisory services to Indian corporates, foreign subsidiaries, and multinational enterprises structured to meet every regulatory requirement under the Income Tax Act, 1961.
Speak with our Transfer Pricing specialists to assess your compliance obligations.

Who Needs Transfer Pricing Compliance in India?

Transfer Pricing Obligations Apply Across a Wide Range of Entities and Transaction Types

Foreign MNC Subs

India Co Overseas

Foreign Joint Vent

Royalty/Service Co

Intragroup Loans

Domestic Group Txns

“Transfer Pricing is not merely documentation it is the disciplined alignment of commercial substance, regulatory compliance, and defensible strategy."

RVG Consulting Private Limited offers end-to-end Transfer Pricing services from documentation and certification to advisory, dispute resolution, and advance pricing agreements.

Each service is delivered with technical precision, regulatory alignment, and a clear focus on protecting your organisation from transfer pricing risk under Indian law.

Transfer Pricing Documentation & Study

We prepare comprehensive transfer pricing studies aligned with the OECD BEPS three tier framework covering FAR analysis, selection of the most appropriate pricing method, benchmarking, and a final Local File structured to satisfy Indian regulatory requirements and withstand assessment scrutiny.

Master File & CbCR Compliance

We assist qualifying multinational groups in preparing and filing the Master File under Rule 10DA and the Country-by-Country Report under Rule 10DB ensuring accurate jurisdiction wise disclosures within prescribed deadlines and in compliance with automatic information exchange obligations.

Transfer Pricing Planning & Advisory

We advise on the design and pricing of intercompany arrangements including intragroup services, loans, royalties, and cost-sharing ensuring commercial structures are tax-efficient, arm's length compliant, and aligned with both Indian law and applicable tax treaties.

Litigation & Dispute Resolution

We provide end-to-end litigation support from drafting submissions before the Transfer Pricing Officer and the Dispute Resolution Panel, to representation before the ITAT backed by technically sound arguments grounded in statute, OECD guidelines, and judicial precedent.

Our Transfer Pricing Services

Why Choose RVG Consulting for Transfer Pricing

Transfer Pricing is a high stakes compliance area where technical depth and regulatory expertise determine whether a position is defensible or leads to costly adjustments.

Regulatory Expertise Grounded in Indian Law

Our team maintains current working knowledge of Sections 92 to 92F of the Income Tax Act, CBDT circulars, ITAT decisions, and the evolving OECD BEPS framework ensuring your compliance positions reflect the latest regulatory expectations, not outdated interpretations.

Deep knowledge of Indian Transfer Pricing regulations

OECD BEPS-aligned documentation approach

Current with CBDT circulars and ITAT precedents

Risk Focused Documentation Methodology

Our documentation process is designed not just to satisfy the statutory requirement, but to actively identify and address pricing vulnerabilities before a tax authority does. Every study we prepare is structured to support your position through assessment, DRP proceedings, and ITAT appeals without requiring post-facto reconstruction.

Audit-ready documentation from day one

Exposure identified before filing, not after

Consistent methodology across all transactions

Integrated Strategic Tax Alignment

We assess transfer pricing positions within your broader international tax profile factoring in withholding tax obligations, treaty application, permanent establishment risk, and GAAR implications. This ensures your intercompany pricing is consistent and coherent across your entire cross border tax structure, not just compliant in isolation.

Transfer Pricing positions aligned with treaty obligations

Withholding tax and PE risk considered

Coherent cross-border tax structure

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Transaction & FAR Analysis

Benchmarking Study

TP Documentation

Certification & Filing

Transaction Mapping & FAR Analysis

We begin by identifying and mapping all international transactions and specified domestic transactions between your entity and its associated enterprises. A detailed Functions, Assets, and Risks analysis is then conducted evaluating what each entity contributes to determine the tested party, appropriate pricing method, and comparability criteria.

Full mapping of controlled transactions

Functions, assets and risks evaluated per entity

Tested party and pricing method identified

Phase 1 of 4

Benchmarking Analysis

Using recognised commercial databases, we conduct a systematic benchmarking exercise to establish the arm's length range for each controlled transaction. Comparable independent companies or transactions are identified, qualitative and quantitative filters applied, and the resulting dataset statistically analysed with every step of the search strategy documented for full reproducibility and regulatory acceptability.

Recognised commercial databases used

Reproducible, transparent search methodology

Statistically validated arm's length range

Phase 2 of 4

Transfer Pricing Documentation

We prepare the complete documentation suite required under Indian law the Local File under Rule 10D, the Master File under Rule 10DA where applicable, and the Country-by-Country Report under Rule 10DB where applicable. All documentation is contemporaneous, structured to address each regulatory requirement, and written to clearly articulate the justification for the arm's length pricing adopted.

Local File, Master File and CbCR prepared

Contemporaneous and audit-ready

Structured for assessment defensibility

Phase 3 of 4

Form 3CEB Certification & Ongoing Advisory

We prepare, review, and certify Form 3CEB under Section 92E accurately disclosing all related-party transactions and filing within the prescribed due date. Beyond filing, we provide year-round advisory support for new transactions, structural changes, Transfer Pricing Officer notices, and assessment proceedings serving as your ongoing compliance partner.

Form 3CEB certified and filed on time

ITR and Tax Audit Report consistency verified

Year round advisory and assessment support

Phase 4 of 4

0 cr

Threshold for mandatory TP documentation

1 %

Penalty of transaction value for non-maintenance

1 cr

Group revenue threshold for CbCR filing

0 / FY

Years of proven financial expertise in wealth management planning.

Frequently Asked Questions

Common Questions on Transfer Pricing Compliance in India

Who needs Transfer Pricing compliance in India?

What is Form 3CEB and when must it be filed?

What are the penalties for Transfer Pricing non compliance?

What is the threshold for Transfer Pricing applicability in India?

What is a Master File and Country-by-Country Report (CbCR)?

Structured Transfer Pricing Compliance Begins Here

Transfer Pricing is a high-stakes area where proactive compliance is significantly more cost effective than reactive dispute management.

RVG Consulting Private Limited provides Transfer Pricing compliance and advisory services to Indian corporates, foreign subsidiaries, and multinational enterprises structured to meet every regulatory requirement under the Income Tax Act, 1961. To discuss your compliance obligations or schedule a confidential consultation with our team, contact us today.