Transfer Pricing compliance and documentation

We provide comprehensive TP compliance and documentation services to help clients meet regulatory requirements while aligning with global best practices. Our services include the preparation of local files, master files, and country-by-country reports in accordance with Indian regulations and OECD Transfer Pricing guidelines. We assist in developing robust documentation that supports the arm’s length nature of intercompany transactions, minimizing audit risks and facilitating transparency. Our team works closely with clients to understand their business models and deliver tailored documentation. With deep technical knowledge and industry insights, our specialists help clients stay compliant, reduce penalty exposure, and navigate evolving regulatory landscapes.

Transfer Pricing planning and operating model effectiveness

We support clients in designing and implementing effective TP policies that are aligned with their commercial objectives and global value chains. We translate business strategies into compliant and efficient TP frameworks with input from tax, customs, and accounting professionals. We provide functional and risk analyses, benchmarking, pricing model design, and alignment of intercompany agreements. We facilitate seamless policy integration into daily operations, enabling multi-jurisdictional consistency. We help businesses future-proof their TP strategies sustainably in a complex regulatory environment through value contribution analysis.

Base Erosion and Profit Shifting 2.0: Pillar II

As jurisdictions around the world begin implementing global minimum tax rules under the OECD’s Pillar Two framework, multinational enterprises (MNEs) should proactively prepare for significant changes. Organizations are still in the early stages of transition to Pillar Two and face the challenge of calculating new tax liabilities, assessing financial statement impacts, and meeting complex global reporting obligations. We support clients through this transformation by providing impact assessments, gap analyses, and implementation support, helping them navigate the evolving global tax landscape with confidence.

Transfer Pricing controversy management and dispute resolution

In an era of heightened transparency and information sharing among tax authorities, we offer comprehensive controversy management services to help clients navigate complex TP disputes with confidence and strategic clarity. We support clients through the full controversy lifecycle—from audit readiness and representation before tax and appellate authorities to resolution through APAs and MAPs. Our team blends technical knowledge with practical dispute experience, delivering tailored strategies that mitigate risk and drive sustainable outcomes in a highly regulated global tax environment.

Digital solution offerings

We integrate advanced technology into our TP services to drive accuracy, efficiency, and compliance. Our digital solutions help automate complex processes, enhance data management, and provide real-time insights—empowering businesses to meet regulatory compliance requirements, manage risks, and align TP operations with evolving global tax standards. Our key tools include: RPT Automation Solution: Our proprietary platform automates the tracking, reconciliation, and compliance of related party transactions across Companies Act, SEBI LODR guidelines, and the Income-tax Act, 1961. It centralizes data, enhances governance, and streamlines reporting. By reducing manual effort and facilitating audit-ready documentation, RPT Automation Solution helps businesses mitigate compliance risks and efficiently meet disclosure requirements. DigiRev™: A proprietary digital solution designed to collate evidence for intra-group services and royalty transactions by scanning emails and extracting relevant information using customized keyword algorithms. DigiRev™ enhances documentation quality, reduces manual effort, and improves data security. https://www.ey.com/en_in/services/tax/digital-strategy/digirev TP Web™: Our documentation platform helps meet BEPS Action 13 requirements through efficient, group-wide preparation of master and local files. It accommodates varying documentation structures and integrates with ERP systems for centralized, automated data collection. Customizable features—such as user-specific access and tailored reporting—enable scalable, secure monitoring and assessment, enhancing consistency, transparency, and compliance. TP Engine: Our ready-to-deploy Operational Transfer Pricing platform is built on SAP and powered by a dedicated tax and TP data model. It manages intercompany transactions end-to-end—covering service allocations, royalties, profit splits, cost sharing, and supply chain analytics. With robust reporting and smart data ingestion, it enables adjustments, journal entries, and price list generation, improving transparency, automation, and compliance across jurisdictions. CbCR Web™: Our dedicated Country-by-Country Reporting (CbCR) tool is developed to support MNEs in meeting CbCR compliance requirements. It enables efficient centralized and automated data collection, validation, and management of CbCr reporting data by seamlessly integrating with commonly used ERP systems. Designed for scalability and accuracy, CbCR Web™ streamlines XML report preparation, automates data aggregation, and aligns with local filing standards.

Who is subject to Transfer Pricing regulations in India?

Transfer Pricing (TP) regulations apply to international transactions between associated enterprises, where at least one party is a non-resident. Certain specified domestic transactions between related Indian entities are also covered under Indian TP regulations. In certain circumstances, transactions with third parties may also fall under Indian TP regulations.

Which compliances are required under Indian Transfer Pricing regulations?

Taxpayers must file Form 3CEB certified by a Chartered Accountant, and, if thresholds are met, maintain contemporaneous documentation including the Local File, Master File, and Country-by-Country Report.

What are the penalties for non-compliance with Transfer Pricing regulations?

Penalties range from 2% to 6% of the transaction value for non-compliance, including failure to maintain documentation or report transaction, and for maintaining and furnishing incorrect details. An additional penalty of INR1,00,000 applies for not filing Form 3CEB. Further penalties may apply for under-reporting or misreporting income due to TP adjustments.

What are the alternate dispute resolution mechanisms available to the taxpayers in India for Transfer Pricing disputes?

Indian TP regulations offer dispute resolution mechanisms such as Safe Harbour Rules, Advance Pricing Agreements (APAs), and Mutual Agreement Procedures (MAPs) to enhance certainty and prevent double taxation.

How can businesses proactively manage Transfer Pricing risks in India?

Businesses can manage TP risks by maintaining strong documentation, conducting regular benchmarking, implementing consistent policies, automating processes through technology, and leveraging APAs, MAPs, or Safe Harbour options for certainty and dispute avoidance.

Transfer Pricing Services

EY India offers comprehensive Transfer Pricing (TP) services, which includes regulatory compliance, policy formation and implementation, and effective controversy management.

Connect with us

What EY Transfer Pricing services can we offer you?

Our integrated approach helps businesses align with global standards, manage tax risks, and streamline cross-border transactions. We support clients from planning and documentation to audits and dispute resolution.

Our services are designed to review, document, manage, and defend clients’ Transfer Pricing policies and processes while aligning them with their overall business strategy.

We collaborate closely with clients to develop proactive, pragmatic, and integrated TP and operating model strategies that address today’s complex tax risks while supporting long-term business goals. Our services span the full lifecycle, from planning and documentation to audit defense and dispute resolution, helping clients stay compliant in a rapidly evolving global tax environment. We offer comprehensive controversy management support, including audit representation before tax authorities and assistance with Advance Pricing Agreements (APA) and Mutual Agreement Procedures (MAP). We also provide robust support on Base Erosion and Profit Shifting (BEPS) initiatives, including both BEPS 1.0 and 2.0 frameworks, enabling clients to navigate international tax reforms.

We provide comprehensive TP compliance and documentation services to help clients meet regulatory requirements while aligning with global best practices.

Our services include the preparation of local files, master files, and country-by-country reports in accordance with Indian regulations and OECD Transfer Pricing guidelines. We assist in developing robust documentation that supports the arm’s length nature of intercompany transactions, minimizing audit risks and facilitating transparency. Our team works closely with clients to understand their business models and deliver tailored documentation. With deep technical knowledge and industry insights, our specialists help clients stay compliant, reduce penalty exposure, and navigate evolving regulatory landscapes.
We support clients in designing and implementing effective TP policies that are aligned with their commercial objectives and global value chains.

We translate business strategies into compliant and efficient TP frameworks with input from tax, customs, and accounting professionals. We provide functional and risk analyses, benchmarking, pricing model design, and alignment of intercompany agreements. We facilitate seamless policy integration into daily operations, enabling multi-jurisdictional consistency. We help businesses future-proof their TP strategies sustainably in a complex regulatory environment through value contribution analysis.
As jurisdictions around the world begin implementing global minimum tax rules under the OECD’s Pillar Two framework, multinational enterprises (MNEs) should proactively prepare for significant changes.

Organizations are still in the early stages of transition to Pillar Two and face the challenge of calculating new tax liabilities, assessing financial statement impacts, and meeting complex global reporting obligations. We support clients through this transformation by providing impact assessments, gap analyses, and implementation support, helping them navigate the evolving global tax landscape with confidence.
In an era of heightened transparency and information sharing among tax authorities, we offer comprehensive controversy management services to help clients navigate complex TP disputes with confidence and strategic clarity.

We support clients through the full controversy lifecycle—from audit readiness and representation before tax and appellate authorities to resolution through APAs and MAPs. Our team blends technical knowledge with practical dispute experience, delivering tailored strategies that mitigate risk and drive sustainable outcomes in a highly regulated global tax environment.
We integrate advanced technology into our TP services to drive accuracy, efficiency, and compliance.

Our digital solutions help automate complex processes, enhance data management, and provide real-time insights—empowering businesses to meet regulatory compliance requirements, manage risks, and align TP operations with evolving global tax standards. Our key tools include:

RPT Automation Solution: Our proprietary platform automates the tracking, reconciliation, and compliance of related party transactions across Companies Act, SEBI LODR guidelines, and the Income-tax Act, 1961. It centralizes data, enhances governance, and streamlines reporting. By reducing manual effort and facilitating audit-ready documentation, RPT Automation Solution helps businesses mitigate compliance risks and efficiently meet disclosure requirements.

DigiRev™: A proprietary digital solution designed to collate evidence for intra-group services and royalty transactions by scanning emails and extracting relevant information using customized keyword algorithms. DigiRev™ enhances documentation quality, reduces manual effort, and improves data security. https://www.ey.com/en_in/services/tax/digital-strategy/digirev

TP Web™: Our documentation platform helps meet BEPS Action 13 requirements through efficient, group-wide preparation of master and local files. It accommodates varying documentation structures and integrates with ERP systems for centralized, automated data collection. Customizable features—such as user-specific access and tailored reporting—enable scalable, secure monitoring and assessment, enhancing consistency, transparency, and compliance.

TP Engine: Our ready-to-deploy Operational Transfer Pricing platform is built on SAP and powered by a dedicated tax and TP data model. It manages intercompany transactions end-to-end—covering service allocations, royalties, profit splits, cost sharing, and supply chain analytics. With robust reporting and smart data ingestion, it enables adjustments, journal entries, and price list generation, improving transparency, automation, and compliance across jurisdictions.

CbCR Web™: Our dedicated Country-by-Country Reporting (CbCR) tool is developed to support MNEs in meeting CbCR compliance requirements. It enables efficient centralized and automated data collection, validation, and management of CbCr reporting data by seamlessly integrating with commonly used ERP systems. Designed for scalability and accuracy, CbCR Web™ streamlines XML report preparation, automates data aggregation, and aligns with local filing standards.

Frequently Asked Questions (FAQs)

Transfer Pricing (TP) regulations apply to international transactions between associated enterprises, where at least one party is a non-resident. Certain specified domestic transactions between related Indian entities are also covered under Indian TP regulations. In certain circumstances, transactions with third parties may also fall under Indian TP regulations.
Penalties range from 2% to 6% of the transaction value for non-compliance, including failure to maintain documentation or report transaction, and for maintaining and furnishing incorrect details. An additional penalty of INR1,00,000 applies for not filing Form 3CEB. Further penalties may apply for under-reporting or misreporting income due to TP adjustments.
Businesses can manage TP risks by maintaining strong documentation, conducting regular benchmarking, implementing consistent policies, automating processes through technology, and leveraging APAs, MAPs, or Safe Harbour options for certainty and dispute avoidance.

Our team

EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients.

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Transfer Pricing Services

What EY Transfer Pricing services can we offer you?

Frequently Asked Questions (FAQs)

Our team

Vijay Iyer

Rajendra Nayak

Paresh Parekh