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

Mar 26, 2026

Amount B Decoded: The Simplified Transfer Pricing Method That's Splitting Jurisdictions in 2025

Amount B was heralded as one of the most practical outputs of the OECD's Two-Pillar project: a simplified, low-cost method for pricing routine marketing and distribution activities that would reduce disputes, particularly for lower-capacity jurisdictions. A year into its optional availability, the reality is more complicated, a patchwork of adoption, opt-outs, and elective procedures that challenges the very simplification it promised.

How Amount B Works

Amount B applies the arm's length principle to "in-scope" transactions involving baseline marketing distributors, wholesalers, sales agents, and commissionaires engaged in routine distribution of goods. Instead of conducting a full benchmarking exercise, eligible distributors apply a fixed return on sales from a reference matrix, with margins the OECD suggests range between 1.5% and 5.5% depending on the distributor type and country-specific adjustments. The Consolidated Report on Amount B was published on February 24, 2025, incorporating the framework into the OECD Transfer Pricing Guidelines.

Amount B is designed specifically for routine distributors. It does not apply to distributors that also perform significant non-distribution functions, own valuable intangibles, or assume material financial risks. Companies must self-assess eligibility before applying the fixed-margin approach.

The Opt-Out Problem

Australia, New Zealand, Norway, and Turkey have all formally opted out of Amount B. This creates a significant bilateral complication: a Singapore-based parent applying the SSA to a transaction with its Australian distributor cannot rely on Amount B because Australia has not adopted it. The receiving jurisdiction may apply its own traditional benchmarking approach, potentially resulting in double taxation rather than the simplification Amount B intended. For MNEs with distribution networks spanning both adopting and non-adopting jurisdictions, a transaction-by-transaction eligibility analysis remains essential.

US Adoption: Elective via Notice 2025-04

The US adopted Amount B on an elective basis through IRS Notice 2025-04, allowing MNEs to rely on the simplified approach for baseline marketing and distribution activities for taxable years beginning on or after January 1, 2025. This partial adoption means that US-parented groups may use Amount B for their outbound distribution relationships where both jurisdictions have adopted the approach, but cannot rely on it universally.

OECD Country Profile Updates: A Rolling Picture

The OECD has been releasing updated country profiles in batches throughout 2025 and into 2026. The third batch, published January 16, 2026, brings the total count to over 78 jurisdictions. Each profile now contains dedicated sections on hard-to-value intangibles and the SSA, providing a jurisdiction-by-jurisdiction overview of adoption status that practitioners can use to map their Amount B eligibility across complex global distribution networks.

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Latest Case Law

Mar 26, 2026

Romania - ÎCCJ Confirms Annulment of €8 Million Tax Assessment on Intra-Group Services

Assessee is an unnamed Romanian corporate taxpayer (represented by STOICA & ASOCIAȚII law firm)

The Romanian tax authority issued assessments disallowing the deductibility of a series of intra-group costs comprising RON 21,771,123 in corporate income tax and RON 17,053,335 in VAT (approximately €8 million in total), plus late-payment interest and penalties on the basis that the expenses were fictitious. The authority treated the intra-group services as lacking economic substance, relying in part on formal deficiencies in the supporting documentation as measured against non-tax legislation.

The taxpayer challenged the assessments before the Bucharest Court of Appeal, which annulled them on 10 June 2025 following extensive evidentiary proceedings, including expert testimony from a panel of three court-appointed experts who also held certified tax consultant qualifications. The ANAF contested the ruling before Romania's highest court.

Assessee's Contentions	Revenue's Contentions	Court's Judgment
The supporting documentation already reviewed by the tax authority substantively confirmed the reality of the intra-group services. Formal deficiencies in the documents assessed under non-tax legislation are irrelevant to the question of actual service provision under tax law. The tax authority cannot question the commercial wisdom or opportunity of intra-group services; only their reality is relevant.	The intra-group costs were fictitious and not backed by evidence of actual service delivery. Formal deficiencies in the supporting documents further undermined the taxpayer's position. The expenses were properly disallowed for both corporate tax and VAT purposes, and the inaccuracy penalties were justified.	The ÎCCJ confirmed the Bucharest Court of Appeal judgment in full. The tax authority's disallowance was unlawful, the supporting documents substantively evidenced real service provision. Formal deficiencies under other legislation are irrelevant for tax deductibility purposes. Courts cannot review the commercial opportunity of intra-group services; this falls outside the tax authority's competence.

Holding -

Romania's Supreme Court (ÎCCJ) confirmed the annulment of the full €8 million assessment. It held that -

1) supporting documents that substantively attest the reality of services cannot be disregarded because of formal deficiencies arising under other (non-tax) legislation;

2) the commercial opportunity or rationale of intra-group services even between related parties falls outside the scope of tax authority review. Only the reality of service delivery is a proper subject of examination.

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Latest Update

Mar 26, 2026

Intangible Asset Management in Multinationals

Importance of Intangible Assets in Multinationals

Intangibles are the principal driver of value creation and a major source of sustainable competitive advantage for most multinationals; technological transformation and the digital revolution have accelerated this phenomenon, allowing intangibles to play a key role in profit generation.

Conversely, their intangible nature has significant challenges regarding valuation and location, which can generate considerable tax risks.

Challenges in Appraising Intangibles

Appraising an intangible asset is complex due to its unique nature and lack of direct comparables, which require specialized methods and detailed analysis. Inaccurate appraisal can lead to discrepancies with tax authorities and Transfer Pricing adjustments, affecting the company’s tax burden.

Management of Intangible Assets and Related Risks

The location of an intangible asset within the corporate structure is a strategic decision with potentially significant tax implications. Since intangibles generate considerable income, tax authorities may question the allocation of this income and the related costs, particularly if they consider the structure was designed to benefit from tax havens. The allocation of intangibles must reflect the economic substance and DEMPE (Development, Enhancement, Maintenance, Protection, and Exploitation) functions within the corporate group to avoid Transfer Pricing adjustments and tax disputes.

Evolution of the International Regulatory Environment

In recent years, international bodies, such as the OECD, have intensified their efforts against tax base erosion and profit shifting, which resulted in implementing measures, such as the BEPS Action Plan, which intends to ensure the taxation of profits where real economic activities take place and value is created.

Recommendations for Multinational Enterprises

In order to mitigate the tax risks related to intangible assets, multinational companies should have:

Comprehensive documentation: Maintain detailed records supporting ownership, appraisal, and location of intangible assets.
Periodic reviews: Regularly evaluate Transfer Pricing policies and ensure alignment with current market practices and regulations.
Application of the DEMPE approach: Address the tax effects of intangibles by focusing on the Development, Enhancement, Maintenance, Protection, and Exploitation (DEMPE) functions.
Expert advice: Have international tax experts who can guide you on best practices and regulatory amendments.

Conclusion

Intangible assets are critical to value creation and sustainable competitive advantage in multinationals. Conversely, their unique nature and the absence of direct comparables in the marketplace hinder their proper valuation. This complexity can lead to disputes with tax authorities and Transfer Pricing adjustments, affecting the company’s tax burden. Therefore, they should support their cost and expense allocations with solid documentation to substantiate the allocation criteria used. These measures will help ensure compliance with tax regulations and reduce risks associated with intangible asset management.

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Frequently Asked

Questions

Frequently Asked

Questions

Frequently Asked

Questions

What is transfer pricing and why is it important?

What industries does NexusPrice support for transfer pricing services?

Can NexusPrice assist us during the transfer pricing audit?

What is GTPIQ and how does it support my business?

How does NexusPrice ensure its benchmarking analysis is compliant?

What are Advance Pricing Agreements (APAs)?

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