Transfer Pricing Services
VCH & Associates provides comprehensive transfer pricing services aligned with Indian transfer pricing regulations, OECD Transfer Pricing Guidelines and global best practices. We support multinational groups and domestic enterprises in managing international transfer pricing, domestic transfer pricing, transfer pricing planning, compliance and litigation, through a practical, compliance-focused and results-oriented approach.
Transfer pricing governs the pricing of transactions between related parties involving goods, services, intangibles and financial arrangements. Under the Indian transfer pricing provisions of the Income-tax Act, 1961 (IT Act) read with OECD Transfer Pricing Guidelines, such transactions must be conducted at an arm’s length price to prevent tax base erosion, profit shifting and to ensure fair taxation across jurisdictions.
As transfer pricing experts and a transfer pricing-specialised firm, VCH & Associates offers end-to-end transfer pricing solutions including transfer pricing documentation, benchmarking studies, audit and assessment support, litigation assistance and advisory services. Our services also include framing and implementing group transfer pricing policies that are robust, defensible and aligned with OECD principles and local regulations.
Our Key Transfer Pricing Services
International Transfer Pricing for cross-border transactions in line with the provisions of IT Act and OECD guidelines
Domestic Transfer Pricing compliance for specified domestic transactions
Transfer Pricing Documentation, including Local File, Master File, and CBCR
Transfer Pricing Audit & Litigation Support before tax authorities
Advisory & Planning to optimize structures and manage risks
By leveraging professional transfer pricing support, businesses can achieve regulatory compliance, mitigate tax disputes and realize the long-term benefits of effective transfer pricing, including enhanced transparency, reduced risk and improved tax efficiency.
Transfer pricing services encompass advisory, compliance and dispute resolution support for transactions between related or associated enterprises. These services include identifying international and domestic related-party transactions, selecting the most appropriate transfer pricing methods, conducting benchmarking studies and preparing statutory documentation such as Local File and Master File. Transfer pricing services also extend to audit representation, risk assessment, advance pricing agreement (APA) assistance and litigation support. The primary objective is to ensure compliance with transfer pricing regulations, manage tax exposure and align business pricing strategies with regulatory expectations under Indian law and OECD principles.
International transfer pricing relates to pricing of transactions between associated enterprises located in different countries. These transactions may involve goods, services, intellectual property, financing arrangements or cost-sharing mechanisms. In India, international transfer pricing is governed by Sections 92 to 92F of the Income-tax Act, 1961, and follows OECD Transfer Pricing Guidelines. The purpose is to prevent profit shifting and base erosion by ensuring that income attributable to India is computed using arm’s length pricing. Proper international transfer pricing compliance helps multinational enterprises avoid double taxation, penalties and disputes with tax authorities.
Domestic transfer pricing in India applies to specified domestic transactions between related parties within the country, particularly where there is a possibility of tax arbitrage. Introduced under Section 92BA of the Income-tax Act, domestic transfer pricing ensures that transactions between related entities benefiting from tax incentives, exemptions or differential tax rates are conducted at arm’s length. Although the scope of specified domestic transactions has been rationalized over time, applicable transactions still require proper pricing and documentation. The objective is to prevent erosion of the Indian tax base and ensure equitable tax treatment across related entities.
Transfer pricing documentation is critical for demonstrating that related-party transactions are conducted at arm’s length in accordance with applicable tax laws. In India, robust documentation helps taxpayers substantiate pricing methodologies, economic analyses and comparability assumptions during assessments or audits. Proper documentation reduces the risk of transfer pricing adjustments, penalties and prolonged litigation. It also ensures transparency in cross-border and domestic transactions, aligns with OECD guidelines and supports consistency in tax reporting across jurisdictions. For multinational groups, well-maintained documentation strengthens governance, enhances audit readiness and provides defensible positions before tax authorities.
Transfer pricing compliance offers significant benefits by reducing tax risk, penalties and exposure to prolonged litigation. It ensures regulatory certainty, improves audit preparedness and strengthens the taxpayer’s position during assessments. Compliance also promotes consistency in pricing policies across jurisdictions, supports better financial reporting and aligns business strategies with tax regulations. For multinational and domestic groups, effective transfer pricing compliance enhances corporate governance, improves stakeholder confidence and minimizes the risk of double taxation. Additionally, it enables proactive tax planning and smoother interactions with tax authorities, contributing to long-term operational and financial stability.
Clients choose VCH for transfer pricing services due to our deep specialisation and focused expertise in transfer pricing. As a transfer pricing-specialised firm, we offer solutions that are strongly aligned with Indian transfer pricing regulations, OECD Transfer Pricing Guidelines and BEPS principles. Our team brings industry-specific experience across multiple sectors, enabling us to deliver transfer pricing strategies that are both technically robust and commercially practical.
With a proven track record in handling transfer pricing audits, assessments and litigation, VCH supports clients across the entire dispute resolution lifecycle. Our experience spans representation before Transfer Pricing Officers, Dispute Resolution Panels, appellate authorities, and higher judicial forums, ensuring effective risk management and defensible outcomes for our clients.
Based in Hyderabad and providing transfer pricing services across India, we work with clients in Bangalore, Chennai, Mumbai, Delhi NCR, Pune, and other major business hubs. Our approach is practical, defensible and results-oriented, helping businesses achieve compliance, reduce transfer pricing risks and build sustainable tax-efficient structures.
