Policy. Documentation. Benchmarking. CBCR. APA. Assessment Representation. When group companies transact with each other, the tax authorities expect those transactions to be supported by a fair and defensible pricing methodology. We help businesses establish that position and document it properly.
Most businesses with intercompany transactions are not trying to avoid tax or create risk.
These transactions may be perfectly legitimate. What matters is whether the pricing behind them can be explained, documented, and supported when it is reviewed. Treating transfer pricing as a year-end compliance task increases the risk of gaps emerging in documentation, reporting, and support. Greenvissage helps businesses build transfer pricing positions throughout the year, so they are ready long before questions arise.
Our services cover every stage of the transfer pricing lifecycle, from policy design and benchmarking to documentation, reporting, and assessment support.
Representation before the Transfer Pricing Officer (TPO) and Dispute Resolution Panel (DRP), supported by documentation, benchmarking, and positions that are already in place and ready to be defended.
We begin by understanding your intercompany transactions, reviewing existing arrangements, and assessing your transfer pricing obligations. From there, we help establish a transfer pricing position that is commercially aligned, appropriately documented, and capable of withstanding scrutiny.
Once the position is established, we prepare the supporting documentation, certifications, and reporting required under Indian transfer pricing regulations. This includes transfer pricing studies, Master File reporting, certifications, and other applicable disclosures.
Where transfer pricing positions are reviewed by the tax authorities, we support the process through documentation, responses, and representation. Because the groundwork has already been done, the focus shifts from rebuilding the position to defending it.




Any company undertaking international transactions with associated enterprises, including parent companies, subsidiaries, or other group entities, is required to comply with Indian transfer pricing regulations.
The arm’s length standard requires related-party transactions to be priced as they would be between independent parties under comparable circumstances. If the tax authority determines that pricing does not meet this standard, adjustments may be made to taxable income, often resulting in additional tax exposure and interest.
The Local File documents India-specific related-party transactions. The Master File provides an overview of the group’s global operations and transfer pricing framework. CBCR reports revenue, profits, taxes, and employee information across jurisdictions. Together, they form India’s BEPS-aligned documentation framework.
An APA is a binding agreement with the tax authority that establishes an acceptable transfer pricing methodology for specified transactions. It provides certainty for recurring transactions and can significantly reduce future transfer pricing disputes.
Tell us about your intercompany transactions. We will assess your current position and identify exactly what needs to be in place.