Global Transfer Pricing
The complete transfer pricing lifecycle — from first health check to audit defence — delivered from India for multinational groups and the advisory firms that serve them.
1Service proposition
Transfer pricing is no longer an annual documentation exercise. Tax administrations in India, the UAE, Europe and Asia now test the substance behind every intercompany price, and multinational groups need policies, agreements, analysis and files that tell one consistent story. TAG Group covers the full lifecycle in one team: we assess where you stand, design the policy, run the economics, document it in every jurisdiction, file what is due, and stand behind the work when it is examined. Delivery runs from our India-based Centre of Excellence with partner-led review, common information requests and defined milestones — direct to corporate groups, co-sourced with in-house teams, or as confidential white-label support for overseas tax, legal and consulting firms.
2One lifecycle — eight services
TP Health Check & Impact Assessment
Map intercompany flows, profile each entity, test current pricing at a high level and size the exposure — with a prioritised roadmap.
Policy Design & Structuring
Group TP policy, pricing models, SOPs and governance, aligned to the value chain and the commercial plan.
Functional & Economic Analysis
FAR analysis, choice of the most appropriate method, tested-party selection and arm's length ranges from global databases.
Intercompany Agreements
Drafting and refreshing agreements so that contracts, conduct and pricing say the same thing.
Documentation
Master File, Local File and multi-country files to a common standard, adapted to each jurisdiction.
Compliance & Filings
Accountant's-report documentation, Master File and CbCR forms in India, the UAE TP disclosure, and CbCR notifications and reports.
Financial Transactions & Intangibles
Loans, guarantees, cash pooling, royalties and IP — with valuation support from our Valuation practice.
Audit Defence & Dispute Support
Pre-audit readiness, responses to TP queries and assessments, and support through APA and appeal processes.
3Business situations that trigger the need
- You have intercompany transactions but no written TP policy or agreements
- A new jurisdiction, restructuring, financing or IP transfer changes how value moves in the group
- UAE Corporate Tax has brought your UAE entities into the transfer pricing net
- Documentation, disclosures and CbCR must be produced consistently across several countries
- A tax administration has opened a TP query, audit or assessment
- An advisory firm needs reliable, confidential TP delivery capacity without adding headcount
- In-house tax teams that need surge capacity, deputation or a second review
4Who this service is for
- Multinational groups with entities in India, the UAE, Europe, Asia or Australia
- Indian groups with outbound subsidiaries and cross-border service, IP or financing flows
- Overseas tax, legal and consulting firms seeking an India-based delivery partner
5Detailed scope of assistance
Planning & policy
- TP health check and risk exposure assessment
- Group TP policy, pricing models and SOPs
- Cross-border transaction structuring and business restructurings
- Intercompany agreements — drafting, review and annual refresh
- Year-end true-ups and pricing adjustments
Analysis & benchmarking
- Functional, asset and risk (FAR) analysis
- Most appropriate method and tested-party selection
- Comparable searches, screening and arm's length ranges
- Royalty, interest-rate and guarantee-fee benchmarking
- Remuneration benchmarking for connected persons
Documentation & compliance
- Master File and Local File, contemporaneous and audit-ready
- Multi-country documentation coordinated from one hub
- India: accountant's-report documentation, Master File and CbCR forms
- UAE: TP disclosure form, Local / Master File and CbCR
- Deputation and second-review support for in-house teams
Controversy & specialist areas
- Pre-audit health check and documentation alignment
- Responses to TP queries, audits and assessments
- Support with unilateral and bilateral APA applications
- Support through appeals, working with our tax practice
- Financial transactions, intangibles and TP-related valuations
6Jurisdictional focus
India
- Accountant's report (Form 3CEB) documentation support
- Master File (Form 3CEAA) and CbCR (Forms 3CEAC / 3CEAD)
- Safe-harbour evaluation and TP assessments
UAE
- Arm's length compliance under UAE Corporate Tax
- TP disclosure form, Local File and Master File
- Connected-person remuneration — via our UAE Desk
Europe, Asia & Australia
- Netherlands, Luxembourg, Singapore and Australia files
- OECD-aligned Local and Master Files
- Coordination with local advisers where required
7Engagement approach & phases
Diagnose
Map transactions and entities; assess the current position and the exposure.
Design
Set or refine the policy, method and agreements that the analysis will support.
Analyse
Run FAR, benchmarking and financial analysis to establish arm's length outcomes.
Document & file
Prepare files and disclosures to a common standard, on the local calendar.
Implement
Embed pricing in systems, SOPs and year-end adjustments; train finance teams.
Defend
Stand behind the work through queries, audits, APAs and appeals.
8Engagement models
Direct engagements
Direct engagements with corporate groups managing multi-country transfer pricing.
Co-sourced delivery
Co-sourced delivery alongside in-house tax teams, including deputation.
White-label support
Confidential white-label support for overseas tax, legal and consulting firms.
Annual TP retainers
Annual retainers covering policy, documentation, filings and year-round queries.
9Databases & tools
We utilize tier-one global financial, benchmarking and transaction databases for economic analysis:
10Typical deliverables
11Selected experience & credentials
Selected clients
12Frequently asked questions
13Service portfolio document
View or download the official 4-page Global Transfer Pricing portfolio overview document below.
14Key contacts
15Connected services
Discuss Global Transfer Pricing with our team
Tell us your situation and we'll map the right scope, team and approach for your business.