Uploaded on May 2, 2025
Transfer pricing refers to the pricing of goods, services, or intangible assets exchanged between two related entities within the same group — known as associated enterprises. These enterprises are typically connected through shared ownership, management, or control, either directly or indirectly.
transfer pricing services
Transfer Pricing
Services
Strategic transfer pricing solutions tailored to
your business.
Index
1. What is Transfer Pricing
2. Applicability of transfer pricing
under the Income Tax Act
3. Documentation assistance
4. Advisory service
5. Disputes handling service
6. Bench marking services
7. About Mercurius
8. How can Mercurius Help You
9. Thank You
What is Transfer Pricing?
•Transfer pricing is the setting of prices for goods, services, or intangible assets
exchanged between related entities within the same corporate group, often under
common ownership or control.
•It becomes an international issue when these transactions occur across borders,
involving multiple tax jurisdictions with different tax regulations.
•When one country adjusts the transfer price for tax purposes, a corresponding
adjustment in the other country is required to avoid double taxation on the same
income.
•The Arm’s Length Principle (ALP) is applied globally to ensure that related entities
price their transactions as if they were unrelated, promoting fair taxation and preventing
tax avoidance.
Applicability of Transfer pricing under the
Income Tax Act
Applicability of Transfer Pricing Regulations
Transfer Pricing Regulations apply to all entities engaged in international
transactions or specified domestic transactions, as outlined in Rule 10D of
the Income-tax Rules, 1962.
Maintaining proper documentation becomes mandatory when:
• The total value of international transactions exceeds INR 1 crore
• The total value of specified domestic transactions exceeds INR 20 crore
This documentation is crucial not just for compliance but also to reduce the risk of tax
disputes. It ensures that transactions between related parties are conducted at arm’s
length prices (ALP) — just as they would be between independent, unrelated
entities — thereby promoting transparency and minimizing tax avoidance.
Specialized Transfer Pricing Services
Documentation Assistance
• Tailored documentation based on client needs
• Functional analysis of business operations
• Transfer pricing methods per Indian laws
• Compliance with arm’s length principle
• Support for master files, local files
Specialized Transfer Pricing Services
Advisory service
• Strategic advice on India
• Expert help in choosing the right pricing
• Optimizing compliant pricing methods
• Support for setting up or improving compliance in India
• Practical solutions aligned with business goals
•
Specialized Transfer Pricing Services
Disputes Handling Services
• End-to-end support through the entire dispute resolution process
• Clear well – well-structured documentation to justify arm-length pricing
• Regular updates and insights to keep you ahead of evolving tax regulations
• Guidance on preventing future disputes through proactive compliance
• Strategic negotiation with authorities to minimize risk and penalties
Specialized Transfer Pricing Services
Disputes Handling Services
• End-to-end support through the entire dispute resolution process
• Clear well – well-structured documentation to justify arm-length pricing
• Regular updates and insights to keep you ahead of evolving tax regulations
• Guidance on preventing future disputes through proactive compliance
• Strategic negotiation with authorities to minimize risk and penalties
About Mercurius
Mercurius is a broad based professional services firm with clientele in 60+
countries, assisting foreign companies with the easy set up and functioning of their
businesses in India.
With a thorough knowledge of Indian regulatory structures as well as international
expectations, we specialize in:
• Company incorporation and structuring
• Regulatory and tax compliance
• Nominee directors and local representation solutions
• Ongoing advisory and post-incorporation support
We are trusted for our reliability, confidentiality and dedication to simplifying entry
into India.
How Can Mercurius Help You?
01 02 03 04
Unmatched
Tailored 15+ yrs Cross Client Cost
Approach Border Support Effectiveness Experience
Thank You
Mercuriusteam.com
[email protected]
m
+91 96677 79615
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