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Transfer Pricing Consultant

Finance

Transfer Pricing (TP) Consultants ensure that prices charged on transactions between related entities — a parent company, its subsidiaries, and associated enterprises across multiple tax jurisdictions — comply with the arm's-length principle under Section 92 to 92F of the Indian Income Tax Act and OECD Transfer Pricing Guidelines. Day-to-day work involves preparing TP documentation under Rule 10D, filing Form 3CEB (the mandatory TP audit report), benchmarking intercompany prices using methods like TNMM (Transactional Net Margin Method), CUP (Comparable Uncontrolled Price), RPM, CPM, and PSM against databases like ProwessIQ, Capital IQ, and Bloomberg, and representing taxpayers in TP audits before the Transfer Pricing Officer (TPO). Senior roles extend to Advance Pricing Agreement (APA) negotiations with the CBDT, Mutual Agreement Procedure (MAP) filings under tax treaties, and BEPS Action 13 compliance (Master File, Local File, and Country-by-Country Reporting for groups above ₹5,500 Cr consolidated revenue). The profession sits at the intersection of tax law, economics, and financial analysis — practitioners must simultaneously argue legal positions, run statistical comparability analyses, and build defensible economic narratives for regulators.