Strategic Transfer Pricing Aligned with Global Business Goals
As global tax frameworks evolve under initiatives like Base Erosion and Profit Shifting (BEPS), Transfer Pricing (TP) has become a priority focus for tax authorities worldwide, including in India. With the increasing complexity of mandatory documentation and cross-border scrutiny, TP compliance is no longer optional—it’s critical.
The enforcement of TP laws has become more stringent, with audits often addressing complex transaction structures and pricing methodologies. These proceedings can be time-intensive, costly, and in some cases, result in double taxation—causing significant financial and operational uncertainty.
At Durity, we bring together a seasoned team of TP specialists who provide both domestic expertise and international perspective. We help businesses design economically sound transfer pricing models, document their policies, and manage disputes effectively. Our approach ensures that your intercompany pricing aligns with both commercial realities and regulatory expectations across jurisdictions.
Our offerings:
Global TP Documentation Include
With tax authorities across the world tightening their focus on Transfer Pricing, robust documentation is not just a regulatory requirement—it’s a strategic safeguard. Properly maintained and consistent documentation helps defend your transfer pricing positions and reduces the risk of adjustments, penalties, and double taxation.
We help businesses prepare and maintain transfer pricing documentation that is both compliant and defensible, aligning with local regulations and international guidelines such as OECD standards and BEPS Action Plans.
Master File and
Local File
Preparation
Developing comprehensive documentation that meets country-specific regulations while maintaining global consistency
Global
Documentation
Strategy
Assisting with the creation of core documentation frameworks that can be efficiently adapted for multiple jurisdictions
Documentation Reviews
Evaluating the sufficiency and defensibility of existing documentation, identifying gaps or compliance risks
Audit-Ready File Preparation
Equipping clients with clear and defensible files for use during tax audits and regulatory inquiries
Transfer Pricing Planning
In an environment of ever-evolving tax legislation and enforcement, a robust and adaptable transfer pricing strategy is critical. At Durity, we help businesses develop and implement compliant, commercially viable TP strategies that align with both local and global requirements.
Our approach focuses not only on setting the right policies but also on ensuring that your documentation remains audit-ready, relevant, and up to date.
Strategic TP Policy Design
Assisting multinationals in creating fiscally efficient and practical TP policies tailored to their operating structures
Adaptation to
Legal or Business
Changes
Updating policies and documentation to reflect changes in local regulations or evolving business models
Transaction-
Level
Implementation
Translating TP policies into actionable pricing at the transaction level, reconciling customs requirements, and automating calculations where feasible
Ongoing
Monitoring &
Testing
Supporting in regular review of transfer pricing outcomes, including variance analysis and risk identification
Guidelines & SOP
Development
Helping businesses establish internal processes and documentation protocols to ensure ongoing compliance and audit readiness
Transfer Pricing Controversy & Dispute Resolution
With the increasing scrutiny of cross-border transactions, TP controversies are becoming more common—and more complex. Disputes often arise over how profits are allocated among jurisdictions, leading to audits, adjustments, and the risk of double taxation.
At Durity, we help multinational companies navigate TP disputes with a strategic and compliant approach—ensuring you’re prepared at every stage, from audit support to appellate proceedings.
TP Audit
Support
Assisting in responding to queries, compiling documentation, and managing proceedings during TP audits initiated by tax authorities
Appellate Representation
Supporting clients in proceedings before the Commissioner of Income Tax (Appeals), Dispute Resolution Panel (DRP), and Income Tax Appellate Tribunal (ITAT)
Strategic Dispute Advisory
Evaluating the sustainability of TP positions and recommending the most suitable resolution mechanisms based on risk and cost analysis
Alternate Dispute Resolution Mechanisms
Mutual Agreement Procedures (MAPs)
Assisting in filing and managing MAP claims to resolve double taxation with treaty partners
Safe Harbour
Rules
Advising on eligibility, procedural steps, and documentation for opting into Safe Harbour provisions
Advance Pricing Agreements (APAs)
Supporting the entire APA lifecycle—unilateral, bilateral, or multilateral—including pre-filing consultations, documentation, and rollback requests
Our Value Chain Management Approach
Tax-Aligned Business Structuring
We assist in realigning functions, assets, and risks across entities to reflect commercial substance and optimize tax outcomes
Integrated Tax &
Operational
Planning
By embedding tax planning into business transformation or supply chain changes, we help improve efficiency while minimizing the overall effective tax rate
Customized to
Your Business
Model
Every business is different. Our strategies are tailored to your unique operating model, industry, and growth plans—offering flexibility and scalability
Enhancing ROI &
Managing Risk
Our holistic approach not only reduces unnecessary tax burdens but also supports risk management and return on investment through smarter, future-ready planning
Durity’s value chain management services are designed to help your business grow confidently—by making tax strategy a core part of your operating framework.
Base Erosion and Profit Shifting (BEPS) Advisory
The OECD’s Base Erosion and Profit Shifting (BEPS) initiative represents a global shift toward tax transparency, economic substance, and fair allocation of profits. With India actively implementing BEPS-aligned measures—such as Country-by-Country (CbC) reporting, interest deduction limitations, and the equalization levy—it’s critical for multinational enterprises (MNEs) to adapt their tax and transfer pricing strategies accordingly.
At Durity, we help businesses assess and strengthen their global tax structures to ensure compliance with BEPS action plans while maintaining operational efficiency.
BEPS Compliance Strategy
Assisting MNEs in evaluating and realigning their group-wide strategies in light of BEPS principles and evolving local regulations
Intangibles Assessment
Evaluating the location, ownership, and functional contribution around intangibles (IPRs, brands, etc.), and ensuring that entities performing Significant People Functions (SPFs) are appropriately remunerated
Diagnostic
Readiness
Reviews
Conducting BEPS-focused health checks to assess the group’s preparedness for transfer pricing compliance, documentation, and audit defense
Equalization Levy & Digital Economy Advisory
Advising on the impact and compliance obligations for digital transactions, especially for non-resident companies with significant economic presence in India
Three-Tiered TP Documentation Support
Master File
A group-wide overview of global operations, policies, and allocation of income
Local File
Detailed analysis of the local entity’s intercompany transactions and TP positions
Country-by-Country (CbC) Reporting
Jurisdiction-wise reporting of revenue, profits, employees, and tax paid, with support in aligning data with global and local filings
At Durity, we combine technical expertise, global insight, and practical guidance to help MNEs manage their BEPS obligations proactively, mitigate risk, and ensure alignment between substance and structure.
Why Durity?
Expert-Led Tax
Advisory
Utilise the expertise of one of India’s top tax consultancy firms to navigate India's evolving tax landscape. Our specialists ensure your business stays compliant while optimising tax strategies
Tailored Tax
Solutions
From direct taxation to GST and international tax compliance, we provide customised tax solutions that align with your business structure and financial goals
Optimised Regulatory
Compliance
Stay ahead of tax regulations with hassle-free compliance management. We handle tax filings, audits, dispute resolution, and advisory to help businesses avoid penalties and legal risks
India-Focused Tax
Expertise
With deep knowledge of India’s tax system and global taxation frameworks, Durity ensures businesses remain compliant both locally and internationally
Durity’s Global Expertise
15+
Years of Industry
Experience
12,000+
Businesses
Empowered
500+
Global Team
Members
50+
Service Offerings
How We’ve Helped Businesses Thrive
Durity’s strategic financial guidance was instrumental in our expansion. They helped us secure funding and navigate complex regulatory hurdles, allowing us to double our market share.
Suraj Akhil
Founder,
E-Commerce Startup
Priya Mehta
Director of Finance,
IT & Consulting Firm
Durity’s support has been invaluable throughout our journey. From startup to established business, they’ve been a constant source of expertise and guidance, helping us achieve consistent growth year after year.
Abbas Khan
MD,
Manufacturing Enterprise
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