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Compliance

Transfer Pricing

Document related-party transactions with a clear commercial rationale.

Related-party deals

Associated-enterprise transactions

Documentation

Agreements, invoices, evidence

Commercial rationale

Pricing method explained

Cross-border

Group transactions

Documented

Method and rationale

Aligned

Agreements, invoices, accounts

Overview

Transactions between associated enterprises

Transfer pricing applies to businesses that transact with associated enterprises, especially in cross-border group structures.

It may cover international transactions and specified domestic transactions, where applicable. Common related-party transactions include management fees, technical service charges, royalty payments, cost sharing, reimbursements, inter-company loans, product sales, support services, software services, marketing support, back-office services, and shared resources.

Management fees and royalties

Software and support services

Inter-company loans

Audience

Who is this for?

Foreign-owned subsidiaries

Foreign-owned subsidiaries with cross-border group transactions.

Associated enterprises

Companies with associated-enterprise dealings.

Group structures

Groups with management fees, royalties, or inter-company services.

The process

What it involves

Businesses must keep documentation covering the nature of the transaction, the relationship between parties, the pricing method, commercial rationale, agreements, invoices, financial data, and supporting evidence. Certification and reporting may also be required in many cases.

Eraqus support includes transaction mapping, record collection, agreement review coordination, TP study coordination, Form 3CEB coordination where applicable, and alignment with accounting and tax records.

01

Map related-party transactions

02

Collect records and evidence

03

Review agreements

04

Document the pricing method

05

Coordinate TP study and Form 3CEB

06

Align with accounting and tax records

Before you begin

Key considerations

01

Mapping all related-party and cross-border transactions.

02

Agreements and invoices.

03

Supporting financial data.

04

Pricing method and commercial rationale.

05

TP study and Form 3CEB coordination where applicable.

After incorporation

Ongoing compliance and the right choice

Transfer pricing should not be addressed only after the financial year ends. Business model, inter-company agreements, invoicing patterns, and accounting records should be aligned from the start.

Transaction mapping
TP study
Form 3CEB
Accounting alignment
FAQ

Frequently asked questions

To transactions with associated enterprises, particularly cross-border group transactions, and to specified domestic transactions where applicable.

Yes. Aligning agreements, invoicing, and accounting from the start is much easier than rebuilding documentation after year-end.

Discuss your requirement with our team

Describe where your business stands and what you plan next. The team will help you understand the structure, documentation, and compliance that fit your situation.

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