Transfer Pricing at Arm’s Length. Value Aligned, Globally Delivered.

From planning to defense, NexusPrice powers cross-border pricing strategies

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Who are we?

At NexusPrice, we help Global businesses turn Transfer Pricing from a compliance task into a strategic advantage. In a world of growing Regulation and Complexity, we make sure your pricing aligns with your goals, manages risk and drives value across borders.

We combine deep expertise with smart tools to deliver accurate, future-ready solutions. For us, Transfer Pricing is not just about rules, it's about clarity, alignment, and long-term success.

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What Sets us Apart

Delivered to 15+ Listed Companies

Served 40+ Multinational Corporations (MNCs)

Completed 300+ Transfer Pricing Projects and 100+ Advisory

5+ Global TP Databases Accessed

Successfully defended & saved over $2B in Disputed Tax Litigations

Regulatory Expertise covering 20+ Jurisdictions worldwide

Transfer Pricing Solutions delivered across 20+ countries

Sector Expertise across 15+ Industries

Leveraging a global network across 50+ countries

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Our Global Footprint, Quantified.

Years in business

Projects Delivered

Jurisdictional Expertise

$0B+

Intercompany Transactions Reviewed

Fortune 500 Companies Advised

What We Do Best?

Whether you’re expanding into a new market, preparing for an audit, or redesigning your global pricing strategy, we're here to support you at every step.

Transfer Pricing Advisory

Strategic design of transfer pricing models, value chain alignment, transaction structuring, and policy formulation.

Economic Analysis & Benchmarking

Comprehensive economic analysis and precise arm’s length range determination using global comparable data and advanced transfer pricing methodologies.

Compliance & Documentation

Jurisdiction-specific compliance, including risk assessments and preparation of Local File, Master File, and CbC reports aligned with OECD and domestic regulations.

TP Litigation & Representation

End-to-end support in audits, defense strategies, dispute resolution, and representation before tax authorities — including MAP and APA proceedings.

Technology & Automation

Leverage automation and tech to deliver accurate, efficient, and compliant transfer pricing solutions.

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Countries.

Global Coverage. Local Expertise.

We deliver end-to-end Transfer Pricing solutions across regions — from Asia-Pacific and North America to Europe, the Middle East, and Africa.

Whether it’s designing TP models, benchmarking, or preparing global documentation, our team combines deep knowledge of local tax laws with a unified, globally consistent approach.

Global Coverage. Local Expertise.

We deliver end-to-end Transfer Pricing solutions across regions — from Asia-Pacific and North America to Europe, the Middle East, and Africa.

Whether it’s designing TP models, benchmarking, or preparing global documentation, our team combines deep knowledge of local tax laws with a unified, globally consistent approach.

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Why choose us?

At NexusPrice, we’re upfront about pricing, deliverables, and timelines, building trust from day one. Our TP solutions align with Indian and global regulations, covering everything from planning and documentation to benchmarking, CbC reporting, and tax authority representation.

Transparent and flexible engagement
Transparent and flexible engagement
Global standards with local execution
Global standards with local execution
Full-spectrum TP services under one roof
Full-spectrum TP services under one roof
GTPIQ powers smart, automated TP decisions
GTPIQ powers smart, automated TP decisions

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How We Work.

We understand your business, craft the right plan, execute it seamlessly, and stay with you every step, no fluff, just results.

Client-Centric Onboarding
Client-Centric Onboarding
We begin with an in-depth understanding of your business model, intercompany transactions, and transfer pricing challenges.
We begin with an in-depth understanding of your business model, intercompany transactions, and transfer pricing challenges.
Scope Definition & Transparent Pricing
Scope Definition & Transparent Pricing
We clearly define the scope, timelines, and deliverables—offering transparent, upfront pricing with no hidden costs.
We clearly define the scope, timelines, and deliverables—offering transparent, upfront pricing with no hidden costs.
Jurisdiction-Specific Approach
Jurisdiction-Specific Approach
Our team strategizes and prepares documentation based on the relevant local regulations and global standards (OECD, BEPS).
Our team strategizes and prepares documentation based on the relevant local regulations and global standards (OECD, BEPS).
Data-Driven Benchmarking & Analysis
Data-Driven Benchmarking & Analysis
We conduct robust economic analysis using global databases and industry-specific comparables to determine arm’s length pricing.
We conduct robust economic analysis using global databases and industry-specific comparables to determine arm’s length pricing.
Review & Risk Assessment
Review & Risk Assessment
We conduct TP health checks, identify potential risks, and suggest mitigations before regulatory scrutiny arises.
We conduct TP health checks, identify potential risks, and suggest mitigations before regulatory scrutiny arises.
Proactive Communication
Proactive Communication
Regular updates, clear milestones, and a dedicated team to ensure transparency and smooth execution throughout the project.
Regular updates, clear milestones, and a dedicated team to ensure transparency and smooth execution throughout the project.

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Our Valuable Insights

Latest Blog

Jul 24, 2025

Understanding the OECD Transfer Pricing Guidelines: A Global Benchmark

Introduction

In an increasingly globalized economy, multinational enterprises (MNEs) conduct business across various jurisdictions. This often involves intercompany transactions that must be priced fairly to ensure tax compliance in each country. The OECD Transfer Pricing Guidelines provide a globally accepted framework to manage such intercompany pricing practices, ensuring that profits are taxed where economic activities generating them are performed.

The Role of OECD in Transfer Pricing

The Organization for Economic Co-operation and Development (OECD) has long been at the forefront of promoting international tax standards. Its Transfer Pricing Guidelines serve as a benchmark for aligning transfer pricing outcomes with value creation. Many tax jurisdictions, including India, have adopted these principles into their domestic regulations.

Key Principles

Arm's Length Principle (ALP): The foundational concept which dictates that intercompany transactions should be priced as if they were between unrelated parties.
Comparability Analysis: Determining comparable's to test the arm's length nature of a transaction.
Selection of the Most Appropriate Method: CUP, RPM, CPM, TNMM, or Profit Split.
Functional Analysis: Analyzing the functions performed, assets used, and risks assumed (FAR) by each party.

Impact on MNEs and Tax Authorities

MNEs use the guidelines to manage their transfer pricing risks and ensure compliance, while tax authorities use them to assess and verify arm's length pricing. The OECD’s work on BEPS (Base Erosion and Profit Shifting) has further strengthened these rules to prevent artificial profit shifting.

India’s Alignment with OECD

India follows OECD guidelines in principle, but there are some variations, especially in dispute resolution and documentation thresholds. However, the arm’s length principle, accepted methods, and the emphasis on economic substance are consistent with OECD standards.

Conclusion

The OECD Transfer Pricing Guidelines continue to serve as a vital tool for both taxpayers and tax administrators. Understanding and applying these guidelines is essential for any multinational operating across borders.

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Latest Case Law

Jul 24, 2025

ITAT Bangalore Holds TP Adjustments Cannot Be Made at Entity Level, Must Be Restricted to AE Transactions

Assesee is MN Dastur and Company Pvt. Ltd.

The assessee is engaged in providing consulting and software engineering services to both domestic and international clients.

The case involves inappropriate transfer pricing adjustments applied at the overall entity level, rather than being limited to specific international transactions.

Assessee’s Contentions	Revenue’s Contentions	Judgement
The assessee contended that the TPO erroneously applied adjustments on the entire turnover of INR 5.99 crore instead of limiting the adjustments strictly to transactions with the AEs, which amounted to only INR 4.80 crore.	The Revenue supported the TPO and DRP’s approach, maintaining that the transfer pricing adjustments made were appropriate and justified under the facts and circumstances of the case.	The ITAT held that transfer pricing adjustments must be restricted solely to international transactions with AEs and should not be applied at the entity-wide turnover level.
The assessee also pointed out procedural unfairness, stating that it was not provided with an opportunity to reconcile or verify the figures used by the TPO, which led to an inflated adjustment.	However, the Revenue did not oppose the remand of the matter, indicating a willingness for fresh verification to address any discrepancies related to AE transaction values.	The Tribunal cited the Supreme Court ruling in Hindustan Unilever Ltd. and the ITAT decision in Tokai Rika Minda India Pvt. Ltd., directing the TPO to re-examine and verify the correct value of AE transactions and recompute adjustments accordingly.

The ITAT Bangalore ruled that TP adjustments must be limited to AE transactions and remanded the matter for fresh verification and fair assessment.

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Latest Update

Jul 24, 2025

Introduction of the Domestic Minimum Top-up Tax (DMTT) in Bahrain

National Bureau for Revenue (NBR) of Bahrain issued the Executive Regulations for the Domestic Minimum Top-up Tax (DMTT). These regulations complement Decree-Law No. 11 of 2024, issued in September, introducing an overall minimum tax of 15% for large multinational enterprises (MNEs) operating in Bahrain.

Summary of Pillar 2 and DMTT

The Pillar 2 rules, developed by the OECD, set a global minimum tax to ensure that MNEs pay a minimum effective tax rate of 15% on profits in all countries. If an MNE has an effective rate lower than 15%, a top-up tax applies, which can be collected through:

Domestic Minimum Top-up Tax (DMTT): A 15% local tax on large MNEs within the jurisdiction implementing this measure.
Income Inclusion Rule (IIR): The main collection mechanism under Pillar 2 rules, where the ultimate parent entity (SPU) accounts for the complementary tax in its own jurisdiction.
Under-Taxed Profits Rule (UTPR): It backstops the IIR by allocating the right to collect the top-up tax to other entities in the group according to a proportion based on the number of employees and the value of tangible assets in their jurisdictions.

Key Aspects of the DMTT Executive Regulations in Bahrain

Revenue Test: MNEs are subject to the DMTT if their consolidated revenue exceeds €750 million in at least two of the previous four fiscal years. The regulations specify that these revenues must be determined according to the MNE’s consolidated financial statements, with certain adjustments, such as including unrealized gains from investments and extraordinary or non-recurring items.
Excluded Entities: The decree-law identifies entities excluded from the DMTT, such as government bodies, international organizations, and non-profit organizations, thus following the OECD recommendations. The regulations provide detailed definitions for these entities and the criteria to be met to be considered excluded.
Permanent Establishments: The regulations include a definition of permanent establishment and detail the calculation of the allocation of income and expenses, following OECD standards and principles. It ensures that branches of foreign entities in Bahrain are properly considered within the DMTT’s scope.
Qualified Domestic Minimum Top-up Tax (QDMTT) and Safe Harbor: If the DMTT implemented by Bahrain meets certain requirements, it is a QDMTT. It would enable the application of safe harbors for MNEs, reducing compliance burdens by deeming the top-up tax due in Bahrain to be zero for purposes of Pillar 2 rules.

Relationship Between the DMTT and Transfer Pricing

Implementing the DMTT in Bahrain significantly implies MNEs’ Transfer Pricing policies. Companies must ensure that their related-entity transactions comply with international standards to avoid tax adjustments that may increase their tax burden to document Transfer Pricing methodologies properly and assess their effects on compliance with the DMTT.

Implications for Multinational Enterprises in Bahrain

The introduction of the DMTT in Bahrain reflects a commitment to OECD initiatives to establish a global minimum tax and align the country with international tax trends. MNEs operating in Bahrain should assess the effects of these regulations on their tax burden and compliance obligations. Companies should review their tax structures and consider possible adjustments to ensure compliance with the new regulations and optimize their regional tax position.

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