Transfer Pricing

Our Services

PwC is well positioned to advise you on a strategy that can help advance your goals within the ever-shifting compliance landscape. Whatever the nature of your business – high-growth entrepreneur, mid-size company or market leader – and whatever your industry, we have the tools, the local presence and the sophisticated, up-to-date regulatory knowledge to help you stay ahead of the game. Our services comprise of the following:

a. Transfer Pricing documentation

  • Develop transfer pricing documentation and defence files, aligned with global and local requirements, coordinated across all the territories in which you operate
  • Adapt to a changing documentation regime – CbCR under the BEPS initiative

b. Representation and litigation support

  • Our self-sufficient litigation team will help you resolve transfer pricing disputes and minimise transfer pricing exposure in future periods.
  • We can coordinate with PwC professionals worldwide to provide effective representation through all phases of controversy resolution,
  • We can also offer advice on the most effective audit defence strategy to pursue and provide technical support,
  • We have a separate page for Tax Controversy and Dispute Resolution.

c. Advisory

  • Our team can advise and assist in complex assignments like Cost Contribution Arrangements, adherence to Transfer Pricing laws and allied laws like GST, Customs, Ind AS, etc.,
  • Our experts can assess your existing transfer pricing policies, evaluate potential risks and advise on pragmatic corrective solutions, keeping in mind your global effective tax rate and tax management strategies

d. Specialised offerings

  • Advance Pricing Agreement (APA): This covers all aspects commencing from developing strategies till conclusion of the APA proceedings.
  • Value Chain Transformation: This was designed to help companies transform the way they do business every step of the way, from initial strategy through final delivery in a tax advantaged manner.
  • Compliance with corporate laws: This is designed to assist companies (listed and un-listed) comply with the requirements under the Companies Act, 2013 and SEBI's listing agreement.
  • BEPS: Aligning the TP policies and transactions in the light of BEPS measures.


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Refer to our Global TP offerings:

Contact us

Gautam Mehra
Leader, Tax and Regulatory Services
Tel: +91 22 6689 1155

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