Transfer Pricing Documentation & Risk Management

Arm's-length compliance, Master File and Local File preparation, and FBR-ready defence by an ACCA & ACA qualified team.

Looking for professional Transfer Pricing Documentation in Sialkot? Trusty Consulting helps businesses that transact with associated companies meet their obligations under Section 108 of the Income Tax Ordinance 2001 — accurately documented, defensible, and ready before the FBR asks. If your business deals with a related party, group company, or overseas associate, this is not optional compliance.

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Professional Transfer Pricing Services

When two connected businesses trade with each other, the law requires that they price those transactions exactly as unrelated parties would. That is the arm’s-length principle, and under Section 108 the Commissioner has the power to redistribute or reallocate income, deductions, and tax credits between associates to reflect what a genuine arm’s-length transaction would have produced.

Therefore, weak or missing documentation is a serious exposure. As an ACCA and ACA qualified firm, we prepare Transfer Pricing Documentation in Sialkot that stands up to scrutiny — supported by proper benchmarking, clear commercial logic, and the exact files the law prescribes.

What Our Transfer Pricing Service Covers

Master File & Local File Preparation

Section 108(3) requires every taxpayer transacting with an associate to maintain a Master File and a Local File containing the prescribed documents and information. We prepare both properly structured, complete, and retained for the required period.

Country-by-Country (CbC) Reporting

Where applicable, the law requires you to keep, maintain, and furnish a prescribed country-by-country report to the Board. We assess whether your group falls within scope and handle the filing correctly.

Arm's-Length Benchmarking

We analyse your related-party transactions and benchmark them against comparable independent transactions, so your pricing has evidence behind it not just an assertion.

Royalty & Intra-Group Charge Review

Since tax year 2024, where royalty is paid to an associate for a brand, logo, patent, trademark, or similar right and you cannot demonstrate that no benefit was conferred on the associate, 25% of your sales promotion, advertisement and publicity expenditure can be disallowed and allocated to that associate. We help you build the evidence file that prevents this.

30-Day Response Readiness

If the Commissioner requests your documentation during proceedings, you must furnish it within thirty days. An extension can be granted on written application, but normally not more than forty-five days. We keep your file ready so that clock is never a problem.

Section 108A Defence Support

If the Commissioner forms the view that a transaction was not at arm's length, he may obtain a report from an independent chartered accountant or cost and management accountant to determine fair market value. We represent you and prepare your technical response.

Who Needs This Service

Our Transfer Pricing Documentation in Sialkot service is built for:

  • Exporters in Sialkot — surgical, sports goods, leather, and textiles dealing with overseas buying houses, agents, or group entities
  • Group companies with common directors or shareholders transacting internally
  • Businesses paying royalty, licence, or management fees to an associate
  • Companies with foreign parent, subsidiary, or sister concerns
  • Importers and distributors buying from related suppliers abroad
  • Any taxpayer that has entered into a transaction with an associate the obligation applies regardless of size

What's Included

  • Related-party mapping — identifying every associate and transaction in scope
  • Master File & Local File prepared to prescribed standards
  • Country-by-country report assessment and filing where applicable
  • Arm’s-length benchmarking study with documented comparables
  • Royalty & intra-group charge defence file
  • FBR notice and audit representation under Sections 108 and 108A
  • Annual documentation refresh so your file never goes stale

Why Choose Trusty Consulting

  1. ACCA & ACA qualified — transfer pricing is technical work, and we apply the standards set by ACCA and ICAP, Pakistan’s top accountancy bodies.
  2. Statute-first approach — every file we prepare is built directly against the wording of Section 108 and the prescribed rules, not generic templates.
  3. Local Sialkot expertise — as your dedicated Sialkot tax consultant, we understand how the city’s export businesses actually structure their overseas relationships.
  4. Defence-ready, not just compliant — we prepare documentation assuming it will be challenged, because that is the only standard worth meeting.

Explore our full range of accounting and tax services at Trusty Consulting.

Our Simple 5-Step Process

  1. Map your associates — we identify every related party and every transaction that falls within Section 108.
  2. Planning & risk optimization — first, we assess your exposure, review your existing pricing, and structure a defensible arm’s-length position within the law.
  3. We explain the plan — next, we walk you through your risk areas and the documentation strategy in plain language before anything is finalised.
  4. We prepare the documentation — once you’re comfortable, we build your Master File, Local File, benchmarking study, and supporting evidence.
  5. We defend and maintain — finally, we handle any FBR query or Section 108A challenge, and refresh your documentation each year.

Get Your Transfer Pricing File in Order

Don’t wait for a notice to discover your documentation is incomplete. Let the ACCA & ACA team at Trusty Consulting prepare your Transfer Pricing Documentation in Sialkot thorough, compliant, and built to withstand challenge.

 

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