Transfer pricing policies of multinational businesses can have a huge impact on the distribution of the taxable profits of such businesses. With increasing globalization, the tax authorities in each jurisdiction are constantly developing measures to protect and increase their jurisdiction tax base. The field of transfer pricing has undergone various complex changes including the dynamic changes in the domestic tax laws, OECD’s work on BEPS and introduction of MLI to be read alongwith the DTAA.

The professionals at KNAV have a thorough understanding of these new advances and believe in keeping up with the constantly shifting transfer pricing developments around the globe in order to assist our clients more efficiently. Our team provides a range of services from advising on the structure of transfer pricing between group countries, to assisting with the compliances in respect of the same, including preparation and filing of annual Accountant Certificate and undertaking country by country reporting.


  • Advisory in strategizing and developing effective transfer pricing policies, including having regard to BEPS provisions with specific reference to intangibles
  • Advisory in aligning global transfer pricing policy with Indian operations and remuneration policy with value chain
  • Evaluate alternate dispute mechanisms including availability of safe harbor, or applying for advance pricing arrangement – unilateral, bilateral as well as multi-lateral
  • Assistance in preparation / review of inter-group transfer pricing services agreements and advising on global documentation
  • Conducting a MLI impact study on global inter-company transactions


  • Global benchmarking: Analyse group structure, undertake FAR analysis and prepare transfer pricing study report/plan
  • Preparing and e-filing Form 3CEB with the Indian revenue authorities
  • Assisting in collating and preparing master file, local file and undertake country by country reporting to the Indian revenue authorities