Transfer Pricing Advisory Services

Helping you price cross-border transactions correctly – so you stay compliant and audit-ready, while being protected against regulatory and financial risks.

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If your business operates across borders, transfer pricing isn't just a technical checkbox - it is a critical part of your risk and tax strategy. From billing offshore entities to allocating shared costs, how you price internal transactions has a direct impact on your bottom line - and on how tax authorities view your business.

In India, we have noticed a considerable rise in transfer pricing disputes over the past few years. With 4,000+ transfer pricing audits annually, non-compliance can lead to adjustments, penalties of up to 100% of tax avoided and litigation risks.

Given the difficulties of BEPS regulations and evolving OECD guidelines, businesses must adopt a proactive, well-documented TP strategy - outlining the requirement for greater accuracy in documentation, risk assessment and dispute solutions.

At MSA, we offer end-to-end transfer pricing and advisory solutions - from compliance to dispute resolution. We support companies in developing strong, well-documented and commercially sound transfer pricing frameworks.

Whether you are preparing for a routine assessment, applying for an Advance Pricing Agreement (APA) or realigning your model after a restructuring - we help you get it right.

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Core Issues Most Businesses Face

We have worked with companies of all sizes and industries - and the challenges often look familiar:

Outdated comparables or reused benchmarks that do not reflect current business realities.
Missing or last-minute documentation, especially when assessments are already underway.
Global policies that do not align with Indian regulations, resulting in inconsistencies and audit exposure.
Business model changes - like digital expansion or restructuring - that leave transfer pricing frameworks out of sync.
And often, simply not knowing where the risks lie until it is too late.

Transfer pricing doesn't usually go wrong because of one big mistake. It is the small gaps - left unchecked - that lead to larger issues later.

MSA's Transfer Pricing Services

At MSA, we do more than just provide you with regulatory compliance, we create transfer pricing (TP) strategies that optimise tax efficiency, reduce litigation risks and support business growth.

Each assignment is led by our senior professionals who understand the bigger picture - and the fine print.

Compliance & Documentation Support

Stay fully prepared with end-to-end documentation that meets both Indian and global TP regulations.

We provide you with end-to-end preparation of Local File, Master File and Country-by-Country Reporting (CbCR).
We offer OECD-compliant reporting to ensure easy global TP alignment.

Benchmarking & Economic Analysis

Get the foundation right with solid comparables and real-world data.

We identify relevant industry comparables, apply filters and make adjustments that reflect your business reality - not just textbook logic.
With each analysis, we build strong, data-backed narratives that hold up in both documentation reviews and assessments.

Transfer Pricing Risk Assessment & Strategic Advisory

Find weak spots early and align pricing with both regulation and your commercial goals.

We help you to pinpoint possible TP risks and structure defensible inter-company transactions.
We create custom TP policies designed to line up with both your business goals and tax regulations.

Value Chain Analysis & Functional Review

Understand where value is created - and how to price it accordingly.

We map key functions, assets and risks across your group to align pricing with actual business activity.
This helps clarify profit attribution, reduce inconsistencies and strengthen your position before regulators start asking questions.

Strategic Advisory for Complex Transactions

Navigate complex cross-border setups with pricing models that reflect real business substance.

We align your pricing models with real business substance, especially after restructures, new entity setups or digital shifts.
We advise on pricing intercompany loans, guarantees, IP licensing and cost-sharing arrangements to keep them compliant and audit-ready.

Transfer Pricing Health Check

Spot issues early - before they show up in a notice.

We review your existing TP files, policies and pricing logic to find gaps or outdated assumptions.
Our review includes practical suggestions so you can act quickly - without overhauling everything from scratch.

Transfer Pricing Audits & Litigation Support

Defend your position with the right mix of strategy, documentation and on-ground representation.

We provide assistance in handling tax audits, reassessments and dispute resolution.
We help you with strategy that is backed by both detailed documentation and strategic insights to effectively safeguard your interests.

Advance Pricing Agreements (APAs) & Safe Harbour

Get long-term clarity and reduce future disputes through formal agreements with tax authorities.

We help you secure long-term pricing certainty through unilateral, bilateral and multilateral APAs.
We offer proactive engagement with tax authorities to eliminate potential disputes before they arise.

TP Structuring for Digital and IP Models

Tailored support for digital-first businesses and IP-heavy group structures.

We help price intangible assets, cloud services and licensing arrangements in line with current global and Indian expectations.
Whether you are scaling a SaaS model or shifting delivery offshore, we make sure your TP structure keeps up.

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Why Choose MSA for Transfer Pricing

Let us take a look at the reasons to choose us - and why our clients stay with us.

Expert-Led, Compliance-Focused

Our team of experienced professionals make sure that your transfer pricing policies are in line with Indian and global tax regulations, reducing audit risks and penalties.

Data-Driven Benchmarking & Risk Assessment

We utilise advanced benchmarking tools and risk analytics to build defensible arm's length pricing, reducing exposure to TP adjustments and disputes.

Proactive Dispute Resolution & APA Expertise

With a solid track record in handling TP audits, litigation and Advance Pricing Agreements (APAs), we help businesses achieve long-term pricing certainty and regulatory compliance.

Not sure where to begin? Call us on +919108004343 or request a quick callback - We'll be happy to guide you.

Key Regulations Governing Transfer Pricing in India: What You Need to Know

Figuring out India's transfer pricing (TP) regulations requires you to clearly understand legal requirements, documentation essentials and risk mitigation strategies.

Sections 92 to 92F of the Income Tax Act, 1961

The foundation of TP regulations aims to ensure that your international and domestic transactions are in accordance with the arm's length principle (ALP).
Covers pricing for inter-company transactions, including books, services, intangibles, loans and cost sharing agreements.

OECD Guidelines & BEPS Action Plan

India aligns with Base Erosion and Profit Shifting (BEPS) Action 13, demanding greater transparency and compliance in TP policies.
As a business you have to substantiate pricing strategies with sturdy documentation to meet global standards.

Master File & Country-by-Country Reporting (CbCR)

Mandatory for multinational enterprises (MNEs) exceeding ₹500 crore in consolidated group revenue.
Helps tax authorities assess global profit allocation and TP risks across jurisdictions to ensure fair taxation.

Secure Your Transfer Pricing Strategy with MSA

In a time of strict regulatory audit and evolving global tax norms, as a business you cannot afford to take a reactive approach to transfer pricing. Non-compliance with TP can lead to costly audits, penalties and prolonged disputes, while a well-structured TP strategy helps your business to have tax efficiency, reduced risks and easy global operations.

At MSA, our expert-driven, data-backed transfer pricing solutions help you understand complex regulations, optimise inter-company transactions and safeguard against tax risks. Whether you need documentation, risk mitigation, audit defense or APA assistance, our custom solutions provide you with complete transfer pricing confidence.