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 27, 2026

Bangalore ITAT: Final Assessment Order Passed Without Giving Effect to DRP Directions Quashed

Symbol Technologies India Pvt. Ltd., engaged in providing software development services to its AEs, was subjected to a TP assessment for AY 2022-23. The TPO proposed a TP adjustment of ₹6.15 crore, against which the assessee filed objections before the DRP. The DRP granted partial relief, reducing the TP adjustment to ₹4.53 crore. However, while passing the final assessment order under section 144C(13), the AO ignored the DRP's directions and retained the original TP adjustment, leading to the present dispute.

Assessee’s Contentions	Revenue’s Contentions	Tribunal’s Judgment
The AO was required to pass the final assessment order strictly in accordance with the DRP's directions under section 144C (13). Since the AO retained the original TP adjustment instead of giving effect to the DRP's relief, the assessment order was invalid	The AO had considered the DRP's directions, but the error occurred while giving effect to them. Therefore, the mistake was only an apparent error that could be rectified under section 154 or the matter could be remanded to the AO.	The Tribunal held that section 144C(13) is mandatory, and the AO has no discretion to ignore or deviate from the DRP's directions. Since the final assessment order did not incorporate the DRP's relief, it was not passed in accordance with law and was liable to be quashed.
The assessee relied on earlier decisions holding that an assessment order passed contrary to the DRP's binding directions is void ab initio and cannot be sustained.	The Revenue argued that the defect was procedural in nature and could be cured through rectification under section 154 without quashing the assessment.	The Tribunal rejected the Revenue's contention and held that the defect was jurisdictional, not procedural and quashed the assessment order as void ab initio.

Ruling Summary -

Bangalore ITAT held that a final assessment order passed without giving effect to the binding directions of the DRP violates section 144C (13) and is void ab initio, since the AO has no discretion to deviate from the DRP's directions.
The Tribunal further held that such a defect is jurisdictional in nature and cannot be cured through rectification under section 154. Accordingly, the final assessment order was quashed.

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Latest Case Law

Jul 30, 2026

Hyderabad ITAT: Time-Barred Assessment: Sec 153(3) Limitation, Not Sec 144C, Applies to Give-Effective Order in Second Round

Vivimed Labs Limited, in the second round of proceedings pursuant to the Tribunal's remand order dated 17.12.2020, received a fresh assessment order dated 13.12.2023 giving effect to the TP issue on advances of ₹252.05 million and ₹8.14 million to its overseas AEs. The AO treated these as interest-bearing working capital advances without examining the Tribunal's direction to verify if they were equity investments, and passed the order beyond the limitation expiring 31.12.2021 rendering both the draft and final assessment orders time-barred under Section 153.

Assessee’s Contentions

Revenue’s Contentions

Tribunal’s Judgment

The giving-effect order dated 13.12.2023 is barred by limitation under Section 153, as the Tribunal's remand order was passed on 17.12.2020 and the limitation to pass the order under Section 153(5) or 153(3) expired on 31.03.2021 and 31.03.2022 respectively.

By way of amendments to the Finance Act 2026, the time limits under Sections 153 and 144C are mutually exclusive, and the draft assessment order dated 14.03.2023 was within time as amended.

Since the remand required only verification of whether the advances were working capital advances or equity investments — not a de novo assessment — the proviso to Section 153(3) applied, reckoning from 01.01.2021 and expiring 31.12.2021. Section 153(4)'s extended period and Section 144C's timelines did not apply to such giving-effect proceedings.

Even the Draft Assessment Order dated 14.03.2023 is barred by limitation, relying on the Tribunal's own order dated 30.04.2026 in the assessee's case for AYs 2014-15, 2015-16 and 2018-19 on identical facts.

The TPO order, draft order, DRP objections, DRP directions and final order were each passed within the respective time limits under Sections 153(3), 153(4) and 144C, and the extended period under Section 153(4) applied since the matter involved a TPO reference.

Since the impugned order was passed on 13.12.2023, both the draft order (14.03.2023) and the final order were held barred by limitation and set aside, following the assessee's own case for AYs 2014-15, 2015-16 and 2018-19.

Ruling Summary -

Where a Tribunal's remand requires only verification of evidence, not a de novo assessment, the giving-effect order's limitation is governed by the proviso to Section 153(3) (12 months from receipt of the order), not Section 153(4)'s extended period or Section 144C's timelines.
A giving-effect order (and its underlying draft order) passed beyond this limitation is liable to be set aside as time-barred, consistent with the assessee's own case in earlier years.

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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

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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?

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What are Advance Pricing Agreements (APAs)?

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