Transfer Pricing

Transfer Pricing

Transfer Pricing (TP) generally refers to intercompany pricing arrangements for the transfer of goods, services and intangibles between associate persons. Transfer Pricing is one of the key areas of scrutiny by the IRB.

From requirements of the tax regulations and guidelines issued by the tax authorities, which are in line with the OECD’s initiatives for transactions between associated persons to be carried out on an arm’s length basis, to the need for businesses to maintain proper documentation including an explanation of the value creation story of a business, BDO’s Transfer Pricing team is well placed to assist our clients in terms of planning, compliance and tax controversy management including the following:


  • Intercompany Transfer Pricing Policy development 
  • Intra-group services and agreeements
  • Risk assessment and agreements
  • Cost allocation techniques 
  • Cost sharing, licensing and intangibles
  • Advance pricing agreements (APAs)


  • Preparation of transfer pricing Documents in compliance with section 140A of ITA and Transfer Pricing Rules 2012
  • Preparation of Master File and Local File
  • Preperation and submission of Country-by-Country Reports (CbCR)

Tax Controversy Management

  • Transfer pricing audit management
  • Transfer pricing dispute resolution
  • Transfer pricing risk management

Read our full brochure to learn more about our Transfer Pricing team and how they can help you.