Intermediate

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.

Transfer PricingArm's Length PrincipleAssociated EnterprisesTNMMForm 3CEBSafe HarbourAdvance Pricing AgreementsIntercompany LoansRoyaltiesCaptive Service Centres
MODULES
5
DURATION
4 Hours
TRACK
Corporate Finance

What You'll Master

Identify when two entities are associated enterprises and which of their transactions fall under Indian transfer pricing rules
Explain the arm's length principle and why tax authorities use it to stop profit shifting
Apply CUP, resale price, cost plus and TNMM to simple Indian examples and pick the most appropriate method
Work out an arm's length range using multiple year data and the interquartile range
Price the common intercompany transactions: management fees, royalties, loans, guarantees and captive services
Understand what goes into Form 3CEB, the master file, the local file and country-by-country reporting
Decide when safe harbour rules or an advance pricing agreement make sense for your group
Run a basic transfer pricing health check on a multi-entity business
Access Level
LEARNER
Everything included
Full Text Playbooks
Actionable Exercises
Mobile Reading Mode
Lifetime Updates

Curriculum Breakdown