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]
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+91 96677 79615