Intercompany Pricing

Transfer Pricing

Comprehensive transfer pricing documentation, benchmarking studies, and compliance services for intercompany transactions across jurisdictions.

Intercompany Transactions
Parent Co (US)
Indian Sub
IT Services
TNMM
Indian Sub
UK Branch
Management Fees
CUP
Parent Co (US)
UAE Entity
Royalties
CUP
UK Branch
AU Entity
Shared Services
Cost+
Indian Sub
Parent Co (US)
Software Dev
TNMM
500+
TP Studies
100%
Audit Success
6
Jurisdictions
$2B+
Transactions Documented
Services

Transfer Pricing Solutions

TP Documentation

Master file, local file, and CbCR preparation compliant with OECD BEPS Action 13 and local regulations.

Benchmarking Studies

Database searches using BvD Orbis, Prowess, and S&P Capital IQ to establish arm's length ranges.

APA Negotiation

Advance Pricing Agreements — unilateral, bilateral, and multilateral — for certainty in intercompany pricing.

Audit Defense

Full representation in TP assessments, appellate proceedings, and Mutual Agreement Procedure (MAP).

Policy Design

Intercompany pricing policies aligned with business substance, value creation, and OECD guidelines.

Economic Analysis

Functional analysis, risk profiling, and characterization of intercompany transactions and entities.

Methodology

Transfer Pricing Methods

We select the Most Appropriate Method (MAM) for each transaction type, ensuring OECD and local compliance.

CUP
Comparable Uncontrolled Price

Commodities, listed products, standardized services

RPM
Resale Price Method

Distribution arrangements, resellers

C+
Cost Plus Method

Contract manufacturing, shared services

TNMM
Transactional Net Margin

IT services, captive operations

PSM
Profit Split Method

Unique intangibles, integrated operations

Workflow

Our TP
Documentation Process

A structured 6-step process from data collection to final filing — ensuring defensible documentation every time.

1
Data Collection

Gather intercompany agreements, financials, and transaction details.

2
Functional Analysis

Map functions performed, assets used, and risks assumed by each entity.

3
Benchmarking

Database search for comparable companies or transactions.

4
Economic Analysis

Apply selected TP method and compute arm's length range.

5
Documentation

Prepare master file, local file, and supporting schedules.

6
Filing & Archival

File Form 3CEB (India), CbCR, and archive for audit readiness.

Why PakalaTax

TP Specialists You Can Trust

Premium Databases

Access to BvD Orbis, Prowess, S&P Capital IQ for best-in-class comparable analysis.

Audit Success Rate

100% track record in defending TP positions during assessments and appellate proceedings.

Cross-Functional Team

CAs, economists, and industry specialists collaborate on every engagement.

Year-Round Support

Not just annual documentation — ongoing pricing policy advice, quarterly reviews, and compliance updates.

Transparent Pricing

Plans & Pricing

Fixed monthly fees • No hidden charges • Cancel anytime

Auto-detected based on your location

Tax Filing & Advisory

From simple individual returns to strategic planning

Basic

Simple individual tax return filing

$50
/month
Individual tax return filing Basic deduction review E-filing submission Email support
Most Popular

Standard

Business tax filing with advisory

$150
/month
Business tax filing Tax advisory sessions GST / VAT filing Named tax specialist WhatsApp support

Premium

Strategic tax planning & compliance

$300
/month
Everything in Standard + Strategic tax planning Full compliance support International tax advisory Dedicated tax manager Priority phone support
Save 15% with annual billing — contact us for annual rates

Compare Plans Side by Side

Find the perfect fit for your business needs

Tax Filing & Advisory
Feature Basic Standard ★ Premium
Individual tax return
E-filing submission
Business tax filing
Tax advisory sessions
GST / VAT filing
Named tax specialist
Strategic tax planning
Full compliance support
International tax advisory
Price $50/mo $150/mo $300/mo
FAQ

Frequently Asked Questions

Any entity with international related-party transactions exceeding prescribed thresholds. In India, TP documentation is mandatory if aggregate international transactions exceed INR 1 crore.

In India, 2% of the value of international transactions for not maintaining documentation. Additional penalties of 50% of tax on adjustments can apply for underreporting income.

A standard single-entity study takes 4-6 weeks. Multi-entity, multi-jurisdiction studies may take 8-12 weeks depending on complexity and data availability.

An APA is a binding agreement between a taxpayer and tax authority fixing the transfer pricing methodology for future years, providing certainty for 3-5 years and eliminating audit risk on covered transactions.

Get Audit-Ready TP Documentation

Don't wait for a notice. Get compliant with expert transfer pricing documentation that withstands scrutiny.

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