Transfer Pricing Advisory Services
Proactive transfer pricing advisory for businesses with related-party transactions. JJJ & Company LLP helps assess transaction structures, select appropriate transfer pricing methods and develop arm’s-length pricing policies before transactions are reported or documentation is prepared. Our advisory approach focuses on aligning commercial arrangements, pricing methodology, benchmarking and Indian transfer pricing requirements so that related-party transactions are supported by a clear and defensible framework.
Trusted Across Diverse Business Sectors
Where does TP advisory add value?
Transfer pricing advisory helps establish the arm’s-length position before a related-party transaction is undertaken, allowing pricing, agreements, supporting analysis and documentation to follow a consistent approach.
Designing the Position
Choosing method and pricing that reflect the arm's-length principle.
- Method selection
- Margin / price design
- Agreement alignment
Structuring Transactions
Advising on how to structure related-party dealings tax-efficiently and defensibly.
- Services and cost allocation
- Royalty and IP charges
- Intra-group financing
The best transfer price is designed, not reconstructed under notice.
When a related-party price is designed on sound method and comparable logic at the outset, the documentation and 3CEB simply confirm it.
Advisory also shapes how transactions are structured — services, intangibles and financing each need a defensible charging basis.
This work leads naturally into benchmarking and documentation, and connects with international tax.
TP Advisory Focus Areas
Where advisory concentrates.
Transfer pricing advisory work we commonly handle.
Transfer pricing advisory may be required for a single transaction, a new business arrangement or ongoing group-wide related-party dealings.
Pricing & Method Advice
Assess the transaction and advise on the appropriate transfer pricing method and arm’s-length pricing position.
Transaction Structuring
Review and advise on related-party arrangements involving management services, intellectual property, financing and other cross-border transactions.
Policy Design
Develop practical group transfer pricing policies that promote consistency between commercial terms, pricing and supporting documentation.
Pre-Transaction Review
Evaluate proposed related-party transactions before execution to identify pricing, documentation and compliance considerations.
Situations where early advice pays off.
New Intercompany Arrangement
The charging basis should be designed up front.
Introducing Royalties or IP
Valuation and method need careful advice.
Intra-Group Financing
Interest and terms must reflect arm's length.
Restructuring the Group
TP consequences should be assessed before change.
Key elements that shape a transfer pricing position.
Function
Understand functions, assets and risks of each party.
Selection
Choose the most appropriate method for the transaction.
Design
Set a price or margin supported by comparable logic.
Agreements
Reflect the position in contracts and documentation.
A structured advisory approach.
The depth of transfer pricing advisory depends on the nature of the transaction, its value, related-party relationship and the group’s risk profile. Our approach is designed to address pricing considerations before they become compliance or dispute issues.
Understand
Map the transaction, parties and functions.
Analyse
Characterise the dealing and select the method.
Advise
Recommend an arm's-length price and structure.
Align
Reflect it in agreements and pricing policy.
Support
Feed the position into benchmarking and documentation.
What helps us give useful TP advice?
A well-designed price is the cheapest defence there is.
Designing the arm's-length position up front means the annual documentation confirms it rather than justifies it after the fact.
Poorly structured intercompany charges — especially IP and financing — are common triggers for adjustment.
Advisory that aligns pricing, agreements and documentation gives the strongest footing at assessment.
Designing a new intercompany arrangement?
Discuss TP AdvisoryWhy groups choose JJJ & Company LLP for TP advisory.
Transfer pricing advice is more effective when commercial arrangements, benchmarking, documentation and compliance follow the same underlying analysis.
Function-Led Advice
Transfer pricing positions are developed around the actual functions performed, assets used and risks assumed by each related party.
Structuring Depth
Related-party arrangements involving services, intellectual property, financing and cross-border dealings are assessed from both commercial and transfer pricing perspectives.
Consistent Policy
Develop a practical group transfer pricing policy that promotes consistency across transactions, entities and financial years.
Defence-Ready
Advisory positions are supported by clear reasoning and evidence so they can be explained and substantiated during subsequent review or scrutiny.
Explore related transfer pricing services.
Common TP advisory questions.
When should we take transfer pricing advice?
How is the transfer pricing method chosen?
Can you advise on royalties and intra-group loans?
Does advisory replace documentation?
Is advisory useful for domestic groups too?
What information do you need to start?
Need to discuss your requirement?
Share a few details and our team can review your requirement and discuss the next step.