⭐ 1. Why Transfer Pricing Matters for Foreign Subsidiaries

Every payment between your Indian subsidiary and your foreign parent must follow India’s transfer pricing rules.
Incorrect pricing or missing documentation can trigger scrutiny, penalties, and delays in cross-border payments.

Foreign founders often face challenges like:

• How to price intercompany services

• What “arm’s length” actually means

• How much markup to apply

• Whether reimbursements are allowed without markup

• How to structure agreements

• How to pass an audit or scrutiny

Our role is simple:
We help you design, document and defend your India transfer pricing — cleanly and correctly.

⭐ 2. What You Get (End-to-End TP Support)

✔ 1. Intercompany Agreement Drafting

We draft and align agreements such as:

• Service agreements

• Cost allocation agreements

• Software development agreements

• IT support agreements

• Management fee agreements

Each agreement is aligned to TP rules + Indian tax expectations.

✔ 2. Benchmarking Study (Local Comparables)

We perform a detailed benchmarking analysis using:

• Indian comparable companies

• Functional analysis

• Transaction analysis

• FAR analysis (Functions, Assets, Risks)

• Selection of appropriate methods

This supports your TP positions and helps during audit.

✔ 3. Transfer Pricing Documentation (3CEB + Local File)

We prepare:

• Form 3CEB

• Local file

• Intercompany transaction details

• Pricing rationales

• Supporting schedules

• Annual TP disclosures

Submitted before statutory deadlines.

✔ 4. Master File & CbCR Compliance

Where applicable, we prepare:

• Master file Part A

• Master file Part B

• CbCR notifications

• Documentation support for global reporting teams

✔ 5. Transfer Pricing Planning

We guide you on:

• Cost-plus models

• Salary recharge models

• Cost allocation models

• Margin justification

• Pass-through transactions

• Reimbursements and tax exposure

Designed specifically for:

• SaaS companies

• Engineering & product development centres

• CRO / healthcare services

• IT back offices

• Global service centres

✔ 6. Intercompany Mark-Up Advisory

We help you determine the correct mark-up for:

• R&D services

• Engineering services

• IT development

• Global support

• Data operations

• Finance/shared services

Aligned with India TP expectations.

⭐ 3. Our Transfer Pricing Process (Simple and Clear)

Step 1 — Understanding Your Intercompany Model

We map:

• Who provides what

• Where value is created

• What risks each entity bears

• How costs and revenue flow

Step 2 — Designing the Pricing Approach

Depending on your business, we recommend:

• Cost-plus

• TNMM

• Fixed mark-up

• Pass-through

• Allocation keys

Step 3 — Drafting/Updating Agreements

We prepare compliant intercompany agreements aligned to tax expectations.

Step 4 — Benchmarking & Comparables

We identify suitable comparables and justify margins.

Step 5 — Preparing 3CEB & Documentation

We prepare:

• Accountant’s report (3CEB)

• Local file documentation

• Transaction-level TP support

Step 6 — Master File/CbCR (If Applicable)

We file and maintain:

• Master file

• CbCR notifications

• Global group alignment

Step 7 — Ongoing Advisory

We also support:

• New service models

• Group invoicing

• Reimbursement design

• Quarterly review

⭐ 4. Why Foreign Subsidiaries Choose KRPR

Because transfer pricing for foreign-owned Indian companies requires a blend of practical and regulatory clarity, not generic theory.

Our strengths:

• 6 CAs, 3 CS, and a legal research team

• 200+ foreign subsidiaries handled

• Strong experience in SaaS/IT/engineering/CRO models

• Ability to link TP with GST, TDS, and FEMA implications

• Boutique, founder-led advisory + detailed execution

Foreign founders trust us because we make TP simple, compliant and defensible.

⭐ 5. Who This Service Is For

• SaaS companies

• Engineering development centres

• CRO & research companies

• IT back-office & support companies

• Any foreign parent with an Indian subsidiary

If you have cross-border transactions, you need transfer pricing.

⭐ 6. What We Need From You (Checklist)

• Intercompany invoices

• Cost/revenue breakdown

• Employee cost details

• Nature of services/product

• Group structure

• Global TP documentation (if any)

• Any existing agreements