Transfer Pricing

Independent Transfer Pricing Valuation Services for Regulatory Compliance and Cross-Border Transactions

Transfer pricing regulations require transactions between related parties to be conducted at arm’s length in accordance with applicable tax laws and international guidelines. An independent valuation is essential to determine fair value, support transfer pricing arrangements, ensure regulatory compliance, and mitigate tax and audit risks. Our experts provide independent and reliable transfer pricing valuation services for domestic and cross-border related-party transactions, helping organizations comply with the Income-tax Act, OECD Transfer Pricing Guidelines, and other applicable regulatory requirements while supporting transparent, defensible, and commercially sound pricing decisions.

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What is Transfer Pricing Valuation?

Transfer Pricing Valuation is the process of determining the arm's length value of transactions between related parties by evaluating the economic substance of the transaction, market conditions, functions performed, risks assumed, and assets employed by the entities involved. A professionally prepared valuation helps businesses comply with transfer pricing regulations, support tax positions, establish fair market values, and ensure that related-party transactions are conducted in accordance with the Income-tax Act, OECD Transfer Pricing Guidelines, and other applicable regulatory requirements.

Cross-Border Related Party Transactions
Transfer of Shares and Securities
Intellectual Property Transfers
Business Restructuring
Corporate Guarantee Transactions

What Decision are you making?

Cross-Border Related Party Transactions

Supports the valuation of international transactions between associated enterprises to ensure they are conducted at arm's length prices.

Transfer of Shares and Securities

Determines the fair value of shares and securities transferred between related parties for transfer pricing and regulatory compliance purposes.

Intellectual Property Transfers

Assists in valuing patents, trademarks, software, and other intangible assets transferred between group entities at arm's length value.

Business Restructuring

Provides valuation support for the transfer of assets, functions, or risks during domestic and cross-border business restructuring exercises.

Corporate Guarantee Transactions

Determines the arm's length value of corporate guarantees provided between related parties for transfer pricing compliance.

Inter-Company Loans and Financing Arrangements

Supports the valuation and pricing of loans, advances, and other financing arrangements between associated enterprises in line with transfer pricing regulations.

Our Valuation Methods, Simplified

Comparable Uncontrolled Price (CUP) Method

Determines the arm's length price by comparing comparable transactions between unrelated parties.

Resale Price Method (RPM)

Determines arm's length pricing based on the gross margin earned on the resale of goods purchased from associated enterprises.

Cost Plus Method (CPM)

Determines the arm's length price by applying an appropriate markup to the costs incurred in supplying goods or services.

Transactional Net Margin Method (TNMM)

Evaluates the net profit margin earned from controlled transactions against comparable independent enterprises.

Profit Split Method (PSM)

Allocates combined profits between associated enterprises based on the relative contribution of each entity.

Discounted Cash Flow (DCF) Method

Used to determine the value of businesses, intangible assets, and certain financial transactions where future cash flows drive value.

Market Approach

Determines value using market-based evidence from comparable companies or transactions where appropriate.

The selection of the valuation or transfer pricing methodology depends on the nature of the transaction, availability of reliable comparables, and the applicable regulatory framework.

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