India transfer-pricing advisory for multinational groups: intercompany transaction review, functional analysis, pricing methods and documentation support.
Can your group explain the functions, risks and economics behind its related-party arrangements? Functional and transaction analysis; Pricing and documentation workstreams; A policy that can be implemented
A defensible transfer-pricing position starts with who performs the activities, uses the assets and bears the risks. Group policy, intercompany agreements, management accounts and actual conduct need to tell a consistent story. The review examines agreed India transactions, identifies gaps between policy and implementation, and establishes the analysis needed for pricing and documentation. Economic benchmarking, certification and dispute support are explicitly defined in the engagement.
Your Indian subsidiary is entering new service, distribution, financing or licensing arrangements with group companies. A group policy needs assessment against local functions and actual results. A business-model change has made existing documentation outdated. Your finance team needs a coordinated approach to India documentation and reporting.
Map related-party transactions and review functions performed, assets used and risks borne. Reconcile the analysis with contracts and operating evidence.
Evaluate pricing approaches and method considerations. Define whether economic benchmarking is needed, required data and database or specialist dependencies.
Develop or review agreed documentation and assess relevant India reporting requirements. Certification, local-file, master-file and country-by-country workstreams are included only where specified.
Compare policy with actual margins, allocations and intercompany charges. Identify monitoring actions, reconciliation gaps and issues for escalation to group tax teams.
A transaction map and functional-analysis summary. A pricing-method assessment with assumptions and data requirements. Documentation or a gap-assessment report for agreed workstreams. An implementation action list for finance and group tax teams.
Group structure, transaction schedules and intercompany agreements. Entity and segment financials, allocation keys and cost records. Existing pricing policies, studies and documentation. Descriptions of operating activities, decisions and risk responsibility.
Submit a short enquiry about your organisation, intended outcome and timetable. Our team reviews the mandate. Responsible professionals, deliverables and fees are agreed before work begins.
Explore the functions, assets and risks that shape your intercompany operating model.
Map activities, decision-making and the contribution made by each party to the controlled transaction. Potential engagement output: A functional profile to inform transaction characterisation and method selection.
Identify the assets used, relevant intangibles and the factual support for each party’s role. Potential engagement output: An asset and documentation map for the agreed transaction perimeter.
Review the agreements against conduct, decision-making and the capacity to bear the identified risks. Potential engagement output: A supported risk profile and a list of inconsistencies to resolve.
Build a consistent account of the value chain, pricing approach, documentation and actual results.
Map controlled transactions, functions, assets and risks; reconcile the profile with intercompany agreements and actual conduct. Potential engagement output: A transaction map and supported functional profile.
Assess method selection, comparability and the economic work needed; specify benchmarking data and specialist dependencies where commissioned. Potential engagement output: A method assessment and defined economic-analysis requirements.
Review local documentation and group-policy consistency; identify the reporting and certification workstreams relevant to the agreed perimeter. Potential engagement output: A documentation gap assessment or agreed documentation package.
Compare policy with segment results, allocations and intercompany charges; identify reconciliation and monitoring actions for the finance team. Potential engagement output: A policy-to-results review with implementation actions.
Tenured Chartered Accountants & Advocates. 15 years in practice, with experience across manufacturing, services, banking, insurance and logistics.
Our background across manufacturing, services and logistics provides context for how activities, assets and responsibilities connect within a business. That professional perspective informs the fact-finding behind an intercompany review.
Understand the contribution of production, sourcing and distribution activities.
Examine who performs the work and how shared-service costs and responsibilities are organised.
Connect contracts and policies with the records and actual conduct of the parties.
Supply chains, capital investment & intercompany arrangements. India expansion and investment structures; Related-party supply and service arrangements; Finance workflows and document controls
Cross-border delivery, operating models & scalable processes. International contracts and payment flows; Group service models and transfer pricing; Workflow automation and AI use-case assessment
Transaction readiness, documentation & controlled operations. Transaction tax and diligence workstreams; Documented approval and reporting workflows; Technology integration with human review
Evidence, reporting & process governance. Tax exposure and transaction documentation; Reporting and reconciliation workflows; AI-assisted document handling with review controls
International operations, service flows & connected systems. Cross-border operating arrangements; Intercompany services and documentation; Operational data and workflow integration
US$ billion · India cross-border M&A. 2024: Cross-border M&A 13.0; 2025: Cross-border M&A 33.2. India cross-border M&A deal value, as reported by EY.
Contracts, taxable presence and intercompany pricing deserve attention before a new operating model goes live. Does your tax and operating structure match how the business actually works?
9 October 2026
An India implementation or documentation review can be scoped around your existing policy, local facts and financial information.
No. Its need, data requirements, database access and specialist support are established in the proposal.
These must be expressly included. The responsible professional confirms applicability, records, timing and fees before accepting the engagement.
EY India M&A report 2026 · Calendar years 2023–2025 · report pages 6 and 8