Precision in International Transactions
Transfer Pricing
Expert transfer pricing advisory covering documentation, benchmarking studies, Advance Pricing Agreements, and compliance filings to ensure your intercompany transactions meet arm's length standards.
Overview
Why Transfer Pricing?
Transfer pricing is one of the most scrutinised areas of international taxation. With the Indian tax authorities increasingly aggressive in their approach to related-party transactions, robust transfer pricing documentation and defensible pricing policies are no longer optional -- they are essential.
Sivadinesh & Co. offers end-to-end transfer pricing services that combine deep technical expertise with practical commercial understanding. Our team has extensive experience in benchmarking studies across services, manufacturing, technology licensing, and financial transactions.
We work proactively with multinational enterprises to design transfer pricing policies that are commercially sound, tax-efficient, and defensible under audit. Our litigation support team has a strong track record of successfully defending transfer pricing assessments before the Tax Tribunal and High Courts.
Talk to an Expert
Get personalised advice from our transfer pricing specialists. The first consultation is always complimentary.
What We Offer
Key Services
A detailed look at the transfer pricing services we provide.
TP Documentation & Compliance
Preparation of transfer pricing documentation including local file, master file, and Country-by-Country Reports (CbCR) in compliance with Indian regulations and OECD guidelines.
Benchmarking Studies
Economic analysis and comparable company selection using Indian and global databases to establish arm's length pricing for all categories of intercompany transactions.
Advance Pricing Agreements (APAs)
End-to-end support for unilateral, bilateral, and multilateral APA applications, including economic analysis, negotiations with CBDT, and rollback provisions.
Form 3CEB Certification
Certification of international and specified domestic transactions as required under Section 92E of the Income Tax Act, with detailed functional and economic analysis.
Domestic Transfer Pricing
Advisory on specified domestic transactions under Section 40A and Chapter X, including transactions with related parties attracting specified deductions or exemptions.
TP Litigation Support
Representation before Transfer Pricing Officers, DRP, ITAT, and appellate authorities with a strong track record of favourable outcomes for clients.
The Advantage
Why Choose Us
Global Benchmarking Expertise
Access to international transfer pricing databases and methodologies ensures your pricing is defensible under both Indian and OECD frameworks.
Proactive Risk Mitigation
We design pricing policies proactively rather than reactively, reducing audit risk and potential penalties significantly.
Successful Litigation Track Record
Our team has successfully resolved high-value transfer pricing disputes before the ITAT and High Courts, saving clients crores in potential adjustments.
Common Questions
Frequently Asked Questions
Next Steps
Discuss Your Transfer Pricing Needs
Our transfer pricing specialists are ready to understand your specific situation and provide tailored advisory. Reach out for a confidential, no-obligation discussion.