Service
Transfer Pricing Compliance & Documentation
At AventaaGlobal, we deliver end-to-end transfer pricing compliance and documentation support for multinational groups across jurisdictions. We help you meet local regulatory requirements, maintain audit-ready documentation, and ensure your transfer pricing positions are consistent, practical, and defensible.
India is an important market for us, but our transfer pricing compliance services are not limited to India. Where a deliverable is jurisdiction-specific (for example, Indian statutory forms), we call it out explicitly.
Local Transfer Pricing Documentation
We prepare robust documentation for cross-border intercompany transactions and, where applicable, domestic related-party transactions, aligned with local rules and global best practices. This typically includes:
Functional Analysis
A structured analysis of functions performed, assets employed, and risks assumed by each entity involved in the transactions—forming the foundation for an arm’s length position.
Comparability Analysis
Evaluation of controlled transactions against appropriate comparables and arm’s length benchmarks, using methods and filters aligned to the relevant jurisdiction’s requirements.
Industry and Business Overview
A clear articulation of the business model, value drivers, supply chain context, and industry landscape—linking commercial reality to the transfer pricing outcome.
Documentation Governance & Audit-Readiness
01
Documentation Calendar & Contemporaneous Readiness
We help set up a jurisdiction-wise compliance calendar and documentation workflow to support timely preparation and availability of documentation, improving readiness and reducing penalty exposure where local rules provide for it.
02
Multi-Tier Documentation Alignment (Local File–Master File–CbC)
We review and align narratives and key numbers across the Local File, Master File, and CbC reporting to reduce inconsistencies—covering transaction descriptions, functional profiles, value chain positions, and financial metrics—so the overall story remains consistent across countries.
03
Audit-Ready Documentation Pack & Financial Reconciliations
We build supporting schedules that tie transfer pricing outcomes to financial statements/management accounts (as relevant), including transaction mapping, segmentation support, and adjustment workings—improving traceability and reducing follow-up queries.
Master File and Country-by-Country (CbC) Reporting
We support group-wide and local requirements for Master File and CbC reporting, including interpretation of thresholds, scope, and reporting responsibilities across jurisdictions.
Master File Preparation
Preparation of the Master File, capturing key information on global group structure, business lines, products/services, intangibles, financing, and intercompany arrangements.
CbC Report Support
Assistance with CbC reporting across scenarios such as:
Ultimate Parent Entity (UPE) reporting in the parent jurisdiction
Alternate/surrogate reporting structures where permitted
Local notifications and consistency checks across filings
Coordination of data inputs and controls to ensure alignment across countries and entities
TP Data Collection, Validation & Reporting Support
We support standardised data-request templates, validation checks, and CbC data QA to improve accuracy and consistency of inputs across jurisdictions.
Specialised Documentation Areas
01
Intangibles & DEMPE Documentation Support
We strengthen documentation around intangibles by supporting DEMPE interviews and analysis, mapping control and decision-making, and aligning narratives with the group’s value creation—particularly where local rules require more granular disclosures.
India-Specific Compliance Support (Where Applicable)
For clients with India operations, we provide support on India-specific statutory deliverables, including:
Assistance with Accountant’s Report in Form 3CEB
Support in compiling and coordinating information for the Accountant’s Report in Form 3CEB for international transactions and specified domestic transactions, and ensuring readiness for e-filing along with applicable audit/tax reporting requirements.
India Master File & CbC Reporting Scenarios
Support for India-linked scenarios, including:
Where the UPE is located in India
Where the Indian entity is designated as an Alternative Reporting Entity (ARE)
Where exchange-of-information limitations affect CbC reporting availability
Where reporting gaps arise despite an exchange framework, requiring follow-up and alignment
Coordination with Prescribed Authorities
Where needed, we assist in managing communications and responses with relevant authorities to support compliance, address queries, and reduce friction during assessments or information requests.
Outcome
Our goal is to help businesses navigate transfer pricing compliance with confidence—through documentation that is practical, consistent across jurisdictions, and defensible under audit scrutiny.