Defensible transfer pricing positions, year on year.
Every cross-border related-party transaction undertaken by an Indian subsidiary is subject to transfer pricing rules under Sections 92 to 92F of the Income Tax Act. The arms length pricing must be documented contemporaneously, certified annually in Form 3CEB, and supported by a transfer pricing study comparing the related-party arrangement to comparable third-party arrangements.
Bizztricks Management Consulting Private Limited has prepared transfer pricing documentation for foreign subsidiaries spanning IT services, captive R&D, financial services, manufacturing, and pharmaceutical groups. We also handle Safe Harbour applications for eligible international transactions providing protection against transfer pricing adjustments at predetermined margins.
What Bizztricks Management Consulting Private Limited Offers
• Annual transfer pricing study functional analysis, economic analysis, and benchmarking
• Form 3CEB preparation, certification, and filing by the statutory deadline
• Comparable company search using databases including Prowess and Capitaline
• Safe Harbour application under Rule 10TD for IT/ITES, R&D, contract manufacturing, and intra-group loans
• Transfer pricing audit support during scrutiny assessment under Section 92CA
• Inter-company agreement drafting and review for pricing, scope, and FEMA alignment
• Management fee, royalty, and cost-sharing arrangement structuring and documentation
• Representation before the Transfer Pricing Officer (TPO) at every stage of assessment