Transfer Pricing

Expert Guidance for Asia, GCC, and Beyond

Managing transfer pricing (TP) is no longer just a compliance requirement – it’s a strategic necessity for businesses operating across borders. With OECD BEPS 2.0 frameworks, economic substance rules, and local TP regulations evolving rapidly, having the right partner is critical.

Get guidance from a professional.

At ScaleX Business, we work with Singapore-based businesses, Middle Eastern enterprises, and global firms entering India to design robust, compliant, and tax-efficient TP strategies.

Cross border

Why Transfer Pricing is Under the Spotlight

Tax authorities worldwide are tightening their grip on related-party transactions. Companies failing to maintain proper documentation face:

  • Heavy penalties and interest charges
  • Double taxation risks
  • Lengthy audit disputes

If you are expanding operations, managing regional headquarters, or operating shared services, a tailored transfer pricing policy is essential.

ScaleX Advantage

Our Regional Expertise

Singapore

Singapore – A Strategic Hub with Stringent Compliance

Singapore remains a preferred regional headquarters location, but its transfer pricing requirements are now more demanding. Key updates include:

  • Mandatory Transfer Pricing Documentation (TPD) for entities exceeding S$10 million in related-party transactions
  • Advance Pricing Arrangements (APAs) for certainty and dispute avoidance
  • Enhanced penalties for non-compliance under IRAS guidelines

We help Singapore-based companies structure intercompany transactions, benchmark services, and prepare TPD that meets IRAS standards.

PC Performance Boost

Gulf & Middle East – Adapting to New TP Frameworks

With the introduction of corporate tax and OECD-aligned TP rules, Gulf-based businesses now face compliance obligations similar to developed economies. This includes:

  • TP disclosure requirements under the UAE’s corporate tax regime
  • Local file and master file preparation for qualifying businesses
  • Alignment with BEPS Action 13 documentation standards

Our team assists regional groups, family offices, and multinationals in free zones and mainland to stay compliant and minimize disputes.

Printer Pro Solutions

India – High-Compliance Market for Foreign Businesses

India imposes strict TP rules for cross-border transactions, especially for foreign companies entering the market. Compliance includes:

  • Filing Form 3CEB with all international transaction details
  • Maintaining local and master file documentation as per income tax rules
  • Addressing scrutiny on royalty, technical services, and cost-sharing agreements

We support Singapore and GCC businesses setting up in India with end-to-end TP compliance, helping avoid costly disputes.

BEPS 2.0 & Pillar Two – What It Means for You

Global tax reforms under BEPS 2.0 and Pillar Two (15% minimum tax) affect businesses headquartered in low-tax jurisdictions like Singapore or operating in GCC free zones.

Our advisory ensures:

  • Alignment with global minimum tax rules
  • Impact analysis on group structures
  • Proactive restructuring to avoid double taxation and penalties
Ready-Made Templates

Common Transfer Pricing Mistakes Businesses Make

Many Singapore-based and Middle Eastern companies face challenges with TP compliance due to:

  • Incomplete or outdated documentation
  • Weak benchmarking studies
  • Late or missing disclosures
  • Ignoring intercompany service charges
  • Overlooking BEPS reporting obligations
ScaleX Advantage

How ScaleX Solves This

ScaleX Business can bridge this gap and assist you with better compliance and all the tools to be prepared and equiped.

  • Proactive audit defense
  • Regional expertise
  • Global alignment
  • End-to-end compliance
  • Advanced benchmarking
Get started

Plan Ahead, Stay Compliant

Transfer pricing compliance is evolving fast. Let us help you stay ahead.

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Our Services

How ScaleX Business can help.

Advisory

Streamlining operations

  • India Market entry advisory
  • Middle East expansion
  • Expansion to Asia (Singapore)
  • Global Expansion
  • ODI & FDI
  • Transfer pricing

Formation

Getting started

  • Business registration
  • Foreign branch
  • Virtual CFO services
  • Singapore Business setup
  • UAE Business setup

Administration

Staying compliant

  • Company secretary services
  • Virtual CFO
  • Accounting & Book keeping
  • Tax compliances
  • HR & Payroll services
  • Goods & Services Tax
  • Business Valuation services
Help Center

Questions? Answers.

ODI refers to Indian entities investing in overseas companies, either through equity or debt instruments. Only eligible Indian companies and certain entities can make ODI under RBI guidelines.

  • ODI: Investments made by Indian companies in foreign businesses

  • FDI: Investments made by foreign entities into Indian businesses

  • Many ODI and FDI transactions fall under the automatic route, but some sectors and investment types require prior approval from RBI or the government.

  • Yes, we handle all reporting obligations including ODI APR filings, FDI reporting (FC-GPR, FC-TRS), and FEMA compliance.