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International Transfer Pricing Advisory in Nashik | Cross-Border Related-Party Transactions | N D Savla & Associates
International Transfer Pricing · Nashik, Maharashtra

Cross-Border Pricing, Set Right From the Start.

Advisory on arm's length pricing of cross-border transactions with associated enterprises, including APAs, safe harbour rules and structuring.

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Cross-border transactions between associated enterprises — sale of goods, services, royalties, financing or cost allocations — must be priced at arm's length, and the compliance burden differs significantly from that for domestic dealings.

At N D Savla & Associates, we advise on pricing policy design, transfer pricing documentation for international transactions, and the safe harbour and Advance Pricing Agreement (APA) options available to reduce future dispute risk.

We also advise on secondary adjustments and repatriation implications that follow once a primary transfer pricing adjustment has been accepted or upheld.

Our International Transfer Pricing Services

International Transaction Identification

Identification of transactions with associated enterprises requiring transfer pricing compliance.

Arm's Length Pricing Advisory

Advisory on pricing policy for cross-border sale of goods, services and intangibles.

Advance Pricing Agreement (APA) Support

Advisory and support in applying for a unilateral, bilateral or multilateral APA.

Safe Harbour Rules Advisory

Evaluation of eligibility for safe harbour rules to reduce transfer pricing scrutiny.

Intra-Group Services & Royalty Advisory

Advisory on pricing and documentation for management fees, royalties and cost allocations.

Secondary Adjustment Advisory

Advisory on secondary adjustment implications following a primary TP adjustment.

Permanent Establishment Interface

Advisory on the interplay between transfer pricing and permanent establishment exposure.

Global Documentation Alignment

Alignment of local transfer pricing documentation with the group's global TP policy.

Our Advisory Process

1

Transaction Mapping

Cross-border transactions with associated enterprises are mapped and categorised.

2

Pricing Policy Review

Existing intercompany pricing is reviewed against the arm's length principle.

3

Compliance Route Selection

Documentation, safe harbour or APA routes are evaluated for the taxpayer's facts.

4

Implementation

The selected route is implemented, including agreements and documentation.

5

Ongoing Monitoring

Cross-border pricing is monitored for continued arm's length compliance.

Why It Matters

✓Cross-border transactions priced with a defensible arm's length rationale
✓Documentation aligned with both local and global transfer pricing policy
✓APA route evaluated where long-term certainty is a priority
✓Safe harbour eligibility assessed to reduce audit exposure
✓Intra-group services and royalty arrangements properly substantiated
✓Secondary adjustment and repatriation implications addressed upfront
✓Permanent establishment risk considered alongside pricing policy
✓Consistency maintained with the wider multinational group's approach

Frequently Asked Questions

An international transaction is generally a transaction between two or more associated enterprises, at least one of which is a non-resident, covering goods, services, intangibles, financing or cost arrangements.
An APA is an agreement between the taxpayer and the tax authority fixing the transfer pricing methodology for specified international transactions for a defined future period, providing certainty and reducing dispute risk.
Safe harbour rules prescribe circumstances in which a taxpayer's declared transfer price will be accepted by the tax authority without further scrutiny, provided the prescribed conditions and margins are met.
Yes, intra-group management fees, royalties and cost allocations between associated enterprises are international transactions and must be supported by arm's length pricing and documentation.
A secondary adjustment treats the excess money arising from a primary transfer pricing adjustment as a deemed advance, which can carry notional interest implications if not repatriated within the prescribed time.
Yes, a bilateral APA involving the treaty partner's competent authority can address double taxation on the covered transactions in both jurisdictions.

Related Services

Domestic Transfer Pricing → Transfer Pricing Documentation → Benchmarking Analysis → Transfer Pricing Assessment → Transfer Pricing DRP → Transfer Pricing Appeals → Tax Health Check → Tax Residency Certificate (TRC) →

Dealing with cross-border related-party transactions?

Tell us about the arrangement — we'll advise on the pricing and compliance route to follow.

Book Free Consultation or send us a message
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