What is specific to US companies
The same intercompany charge is examined by India and by the IRS under Section 482, often reaching different answers. India and the US conclude bilateral advance pricing agreements, which can fix the method for five future years with roll-back, and are worth considering for large captive centres.
The IRS tests the same transaction under Section 482; India and the US conclude bilateral advance pricing agreements.
Our services
How SU and Company helps
We price, document and defend intercompany transactions on the Indian side.
- Functional analysis and benchmarking
- Intercompany agreements review
- Accountant's report and documentation
- Year-end true-ups
- Transfer pricing assessments
Questions
Can transfer pricing disputes be settled in advance?
Yes, through an advance pricing agreement with the Indian tax authorities, bilateral where the treaty partner participates.
General information as at 5 November 2026, not advice for a particular case. Indian and US rules change often; confirm the current position before acting. US law points should be confirmed with a US adviser.