"The Transfer Pricing Experts"





VSTN Consultancy Private Ltd is a boutique Transfer pricing firm with extensive expertise in the field of international taxation and transfer pricing.

Our offering spans the end-to-end Transfer Pricing value chain, including design of intercompany policy and drafting of Interco agreement, ensuring effective implementation of the Transfer Pricing policy, year-end documentation and certification, BEPS related compliances (including advisory, Masterfile, Country by Country report), safe harbour filing, audit defense before all forums and dispute prevention mechanisms such as Advance Pricing agreement.

We are structured as an inverse pyramid where leadership get involved in all client matters, enabling clients to receive the highest quality of service.

Being a specialized firm, we offer advice that is independent of an audit practice, and deliver it with an uncompromising integrity.

Our expert team bring in cumulative experience of over four decades in the transfer pricing space with Big4s spanning clients, industries and have cutting edge knowledge and capabilities in handling complex TP engagements.



Transfer Pricing Advisory

Designing intercompany policy

Drafting intercompany agreements

Price setting through benchmarking

Tax efficient structuring of international transactions (tangible, intangible, financing & services) & transaction flows


BEPS related Services

Preparation of Masterfile in accordance with the Indian regulations for both Indian MNCs and Foreign MNCs

Support for country by country reporting where the consolidated Turnover of the Multinational Group exceeds EUR 750 million (INR 6400 crores)

Risk assessment of the Group's transactions based on the key parameters

IP Structuring/ DEMPE Analysis


Transfer Pricing documentation and Form 3CEB

Preparation of detailed Transfer Pricing documentation (local file) where the value of the international transaction / specified domestic transaction exceeds INR 1 crore (10 million)

Issuance of Accountant’s report in Form 3CEB by a Chartered Accountant irrespective of any threshold.



Conduct searches in databases to identify appropriate comparables as that of the tax payer.


Safe harbour

Evaluating the applicability, consequent filing of safe harbour application (Form 3CEFA) and subsequent representation before the tax authorities.


Due diligence

Review of business model, intercompany transaction, previous years’ documents, TP orders, agreements, audit positions taken and offer advice to reduce the risk exposure.


Advance Pricing Agreements

Proactive way to eliminate future litigation for covered transactions once the agreement is signed between the CBDT and the Tax payer, for 5 forward looking and 4 rollback years. We offer end to end support on APA including post conclusion support, filing of annual compliance report and audit.



Audit defense before all forums - Transfer Pricing officer, Dispute Resolution Panel, Commissioner of Income Tax (Appeals) and Income Tax Appellate Tribunal.

Formulate audit defense strategy, preparation of submissions / appeal documents, briefing of senior counsel, in case of High Court & Supreme Court.


Other services

TP comfort letters / Memo for auditors

FIN 48 assistance – quantification of TP exposure on uncertain tax positions

Related party compliances arising on account of SEBI Listing Obligations, Disclosure Requirements & Companies Act requirement

Cost benefit analysis documentation for intra group payments - Royalty and Management charges

Pillar 1 & 2 impact Analysis


We have a team of experts who have more than a decade of experience in Transfer Pricing and will support client engagements under the leadership of Nithya Srinivasan.

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