Understanding Transfer Pricing Basics for Multi Entity Businesses
The moment a business has two entities under common control, every invoice between them becomes a tax question. A holding company charging its operating subsidiary a brand fee, an Indian captive billing its US parent for software development, a promoter's trading firm buying raw material for the listed company: all of these are transfer pricing transactions, and the Income Tax Department will test each one against what unrelated parties would have agreed. This course teaches the mechanics from the ground up. You will learn who counts as an associated enterprise, what the arm's length principle actually requires, how the six prescribed methods work with worked Indian numbers, how the common intercompany transactions (services, royalties, loans, guarantees, captive service centres) are priced, and what compliance looks like in practice: Form 3CEB, the master file and local file, safe harbour rules, advance pricing agreements and what happens when the Transfer Pricing Officer disagrees. Built for CFOs and treasury teams, growth-stage founders setting up overseas or group entities, and corporate strategy and BD teams structuring intra-group deals.