With increased information sharing across borders and regulators having greater access to businesses and industry related information, MNEs are forced to operate in an environment of unprecedented complexity and uncertainty. The increased volume and variety of intercompany transactions in midst of a constantly evolving transfer pricing regulatory landscape, accompanied by increased enforcement activities worldwide has made it incumbent for MNEs to have access to experienced transfer pricing professionals capable of proactively taking steps to identify transfer pricing risks, mitigating litigation and handling the scrutiny proceedings as initiated by regulators. Further, with the dynamic thrust of OECD towards implementation of BEPS, MNEs are required to ensure compliances with BEPS Action Plans and realign their transfer pricing matrix in line with the latest trends.

NDM has proven track record and capabilities of providing entire gamut of transfer pricing solutions tailored to meet the business objectives of our clients. NDM has the right blend of leadership capabilities and execution teams to handle transfer pricing solutions including planning for new related party transactions, arm’s length comparability, transfer pricing documentation (as prescribed under the India transfer pricing tax laws). We also have capabilities and experience of handling the litigation support, assisting with alternate dispute resolution routes (APAs, MAPs, Safe Harbour Rules).

NDM has capabilities to ensure that the information disclosure under the Country-by-country reporting is appropriately done while factoring the intricacies involved in cross-border transactions of MNEs.

Our Service Offerings



Transfer pricing planning

Evaluation of alternative business structure from a transfer pricing perspective

Compliance and documentation

Providing support in meeting transfer pricing compliance requirements, and assistance in all aspects of documentation preparation and compliance including certification

Controversy & Litigation Management

Assistance in handling notices/ letters from tax department, filing of submissions before officers, negotiation of Advance Pricing Arrangement, handling competent authority negotiations and transfer pricing audit management.

Managing risk

Identification of possible risk areas and assistance in circumventing possible future inquires from revenue authorities by assessing the current transfer pricing policies

Integrated Tax Planning

Providing insights that present international business with the opportunity to comprehensively asses their tax position.

India TP Landscape- Compliances Overview

  • Transfer Pricing Documentation (transfer pricing study) as prescribed under India transfer pricing laws
  • Accountant’s Report in Form No. 3CEB
  • Master File in Form 3CEAA and 3CEAB
  • Country-by-Country Report in Form 3CEAC and 3CEAD
  • Global Transfer Pricing Compliance – Regional/ Country comparable studies and filings adhering to OCED guidelines and local regulations (NDM has access to all major Indian and Global databases/ Software such as Prowess, Capitaline TP, Ace TP, Amadeus, Compustat, Kt-MINE, Royalty Range, Royalty Stat, Orbis, Osiris, IBISWorld, Factiva, One Source, Loan Connector)
  • Transfer Pricing Comfort Letters/Memorandum for statutory auditors
  • FIN 48 Assistance – Quantification and Opinion on Transfer Pricing exposure and uncertain tax positions.
  • Transfer pricing analysis and Board meeting presentation for listed companies from regulatory and secretarial perspective

Litigation Support

NDM has seasoned professionals with vast experience of handling transfer pricing matters including litigation support and representation before:

  • First level authorities – Transfer Pricing Officers (TPO)/ Assessing Officers (AO)
  • Dispute Resolution Panel (DRP)
  • Appellate Authorities – Commissioner of Income Tax (Appeals) [CIT(A)], Income Tax Appellate Tribunals (ITAT), High Court, Supreme Court
  • Support with respect to penalty abeyance, rectification, re-assessment, revision, remand, order giving effect, stay of demand proceedings


Further, we also have experience of handling alternate dispute resolution mechanisms for MNEs such as Advance Pricing Agreement (APA), Mutual Agreement Procedure (MAP) and Safe Harbour Rules (SHR):

  • Cost benefit analysis and optimisation calculations for decision making;
  • Preparation and filing of application in prescribed forms;
  • Representation, submissions and liasioning with authorities;
  • Application renewals;
  • APAs – both unilateral & bilateral
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