In an interconnected global economy, transfer pricing sits at the centre of tax governance and risk management. It goes well beyond a compliance checkbox — done properly, it's what lets you defend intercompany pricing when a tax authority asks hard questions. LEAPRO delivers end-to-end transfer pricing services that keep intercompany transactions aligned with Indian regulations, OECD guidance and international practice, while staying commercially defensible in front of the people who actually review it.
Most TP adjustments and penalties trace back to one root cause — the documentation doesn't match commercial reality. These are the patterns we see most often.
| Common Mistake | Why It's Risky | How LEAPRO Prevents It |
|---|---|---|
| Benchmarking done after year-end | Comparables are selected after transactions are already complete, so pricing is locked in before the adjustment risk is even assessed | Pre-year benchmarking, with pricing bands set before transactions execute |
| Wrong tested party selected | The Indian entity is chosen as tested party when the foreign parent would have been simpler to benchmark, raising adjustment risk unnecessarily | Functional analysis to identify the least complex party before making that call |
| Functional analysis doesn't reflect reality | Documentation claims full risk-bearing when the company operationally carries limited risk — a mismatch that invites adjustment | Interview-based FAR analysis, documented with evidence, board minutes and contracts |
| Safe harbour overlooked when eligible | Full TP risk and documentation cost are carried when a safe harbour option was available at an acceptable margin | Eligibility assessed upfront, with a cost-benefit comparison against full documentation |
| Domestic TP ignored | Specified domestic transactions with related parties go undocumented, creating exposure under Section 92BA | Domestic transactions identified upfront, with documentation prepared wherever thresholds are exceeded |
| What Sets Us Apart | What It Means for You |
|---|---|
| OECD and BEPS aligned | Our methodology follows OECD Transfer Pricing Guidelines and the BEPS Action Plans that shape how disputes get decided |
| Pre-year benchmarking | Pricing bands are set before transactions happen, not reconstructed afterward when the risk is already locked in |
| Commercially defensible documentation | FAR analysis built on interviews, board minutes and actual contracts — not a templated narrative |
| Integrated with tax compliance | TP documentation coordinated with your ITR filing, withholding tax and international tax planning as one process |
Get ahead of it with pre-year benchmarking and documentation that actually holds up.
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