Anshul Sharma

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What is transfer pricing and how does it work for MNCs?

Transfer pricing is a method Multinational Corporations (MNCs) use to set prices for goods, services, or intellectual property traded between their own subsidiaries in different countries. For example, an Indian IT company uses transfer pricing to decide software service charges provided to its US-based parent company.

To decide ‌fair pricing, MNCs follow the arm’s length principle. It requires ‌companies to price such transactions as if they were dealing with independent parties in a competitive market.

This principle gives MNCs two broad benefits: to allocate profits fairly across various jurisdictions and ensure taxes are paid where the actual economic activity and value creation occur.

Why do transfer pricing rules matter for MNCs?

The transfer pricing rules avoid double taxation and save companies from costly audit penalties. Here’s more information about them:

Tax compliance across multiple jurisdictions: Transfer pricing ensures that companies report profit where economic value is created. To decide each entity’s contribution to the profit, companies use functional analysis. It breaks down which specific entity performs key tasks, employs assets, and assumes the most risk.

Avoiding double taxation on intercompany transactions: Without a transfer pricing policy, income can get taxed in two different countries. Proper documentation resolves these cross-border disputes.

Managing audit risk and penalties: Tax authorities, such as India’s Transfer Pricing Officer (TPO) examine financial records rigorously to verify compliance with the arm’s length principle. If MNCs do not provide the required documentation within a 30-day window of a request, it can lead to penalties ranging from 20% to 40% in some jurisdictions.

What are different transfer pricing methodologies?

To establish an arm’s length price, MNCs select one of the five methods recognized by the OECD and global tax authorities. Here are the common methods and examples:&nbsp;

The following table summarizes the five OECD-accepted transfer pricing methods and the specific business scenarios where they are typically applied:

What transfer pricing documentation do MNCs need

Multinational corporations must maintain a three-tier documentation structure to comply with the BEPS Action 13 global standards. It is an OECD/G20 initiative that requires multinational companies to provide detailed data on income, tax payments, and business activities in different jurisdictions.

The master file summarizes the global business group. It covers the organization’s structure, financial activities, supply chain, and financial or intangible assets between subsidiaries. In India, every constituent entity of an international group must maintain a master file to help tax authorities understand the group’s global tax position.

This file focuses only on ‌transactions happening within a specific country. It contains a Functional Analysis (FAR) describing the functions performed, assets used, and risks assumed by each party. It also includes the transfer pricing method used to prove that local transactions meet the arm’s length standard.

Country-by-Country Reporting (CbCR) obligations

CbCR is a specialized annual prepared by MNCs with annual consolidated revenue exceeding €750 million (or ₹6,400 crore in India). The report contains a simple table that describes how much profit was made, how many people were employed, and how much tax was paid in every single country where the company operates.&nbsp;

This report makes it easy for the tax authorities to understand if the company is earning most profits in one country but shifting them to another low-tax country to reduce its liability.

How to build a transfer pricing strategy for your business

To build a transfer strategy for your business, you must follow these five important steps:

Step 1: Map all related party transactions

Identify every global intercompany transaction, including the transfer of goods, services, and intellectual property. Also check for complex arrangements such as intercompany loans, IP licenses, and cost-sharing agreements

Step 2: Select the appropriate pricing method for each transaction

Match each transaction type to the most suitable of the above five OECD-recognized pricing methods. Choose the one that aligns with the nature of the transaction and provides the most reliable arm’s length result.

Step 3: Conduct benchmarking analysis using transfer pricing data

Check professional databases like ProwessIQ or CapitalineTP in India, or Orbis for global transfer pricing data. Use the data as a benchmark to establish an arm’s length range.

Step 4: Document your transfer pricing policy

Prepare a document that includes a thorough functional analysis (FAR) and an economic analysis of your transactions. Include roles, risks assumed, and assets employed by each entity involved. Be proactive in preparing the documentation; don’t wait until the audit.

Review your transfer pricing policy annually to ensure it remains relevant to changing business conditions. Your pricing also remains defensive against changing regulatory environments and adapt to internal organizational changes.

What are global transfer pricing rules across major jurisdictions

These are the three most important jurisdiction transfer pricing rules you must know:

The OECD Guidelines are the global standard for transfer pricing, followed by most countries. When a business aligns with these standards, it can avoid double taxation and ensure that two different governments do not tax its profits twice.

The OECD transfer pricing guidelines are updated regularly, the most recent being in January 2022, which provided improved guidance on financial transactions and hard-to-value intangibles.

In India, Sections 92 to 92F of the Income Tax Act, 1961, and Rules 10A to 10E govern transfer pricing. Companies must justify their pricing to a dedicated Transfer Pricing Officer (TPO) who conducts rigorous audits of intercompany transactions to verify they are aligned with the arm’s length principle. This means they must have a solid audit trail of every transaction in India.

India also offers Safe Harbour rules for specific sectors, which allows companies to use pre-defined margins acceptable ‌without a detailed audit.

Transfer pricing rules in the United States

The IRS Section 482 governs transfer pricing in the United States. It allows the Internal Revenue Service (IRS) to reallocate income or deductions to verify the true taxable income of related parties.

The IRS penalizes companies for substantial or gross valuation misstatements, which can reach 20% to 40% of the additional tax owed. To reduce these risks, many MNCs pursue Advance Pricing Agreements (APAs), which provide prospective tax certainty for five years.

How does transfer pricing affect cross-border payments

While managing transfer pricing, stay mindful of these cross-border payment compliance requirements:

Managing cross-border payments between related entities? Skydo provides transparent fee structures and automatic FIRC generation to support your compliance documentation.

How Skydo helps MNCs manage international payments

One part of a transfer pricing policy is international payments, which requires significant compliance efforts. <a href="https://www.skydo.com">Skydo</a> is a specialized payment infrastructure that takes end-to-end care of this part.

It is not a transfer pricing advisor, but it provides you the tools to view the actual financial flows, document them, and keep them audit-ready.

Integrating Skydo also streamlines the local file requirements through the following features:

Ready to simplify your international payment documentation? Open a Skydo account in minutes and get compliant FIRCs for every transaction.

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Why Does the RBI Regulate Foreign Exchange in India?

The RBI regulates foreign exchange across India to maintain the overall economic stability of the country and ensure that cross-border transactions remain transparent. Without regulation, a sudden or large foreign exchange flow might disrupt the Indian Rupee, which contributes to economic instability.&nbsp;

Here is a more in-depth take on why the RBI regulates foreign exchange:

Who are the Key Participants in India's Forex Market?

To understand the role of RBI in the money market, it is also important to know which other participants are involved:&nbsp;

Authorised Dealer Banks of Category I are commercial banks that usually facilitate full forex services. On the other hand, AD category II entities are involved in money changing activities and handle limited transactions, e.g. currency exchange and small remittances.&nbsp;&nbsp;

These are typically the primary users of the foreign exchange market. Exporters, importers, retail investors, individual remitters, corporates, etc., drive the <a href="https://www.skydo.com/blog/forex-and-its-impact">forex market</a> daily and actively.&nbsp;

SEBI-registered foreign institutional investors under the FPI guidelines and FEMA regulations bring capital to the Indian market, which boosts the Indian economy. For example, till January 2026, the primary and secondary markets in India witnessed an inflow of $6.41 billion and $20 billion, respectively, which added to the economic strength of India.&nbsp;

What is the Role of RBI in India's Foreign Exchange Market?

Apart from managing interest rates in India, the RBI oversees foreign exchange transactions and sets the rules for cross-border dealings under FEMA.

Now, you may wonder how exactly the RBI controls foreign exchange in India. For this, take a look at its four key roles to control it:

The <a href="https://www.skydo.com/blog/compliance-guideline-for-inward-remittance">FEMA of 1999</a> is a modernised law regulating all foreign exchanges in India, replacing its predecessor, the Foreign Exchange Regulation Act (FERA). Under FEMA, the RBI formulates different policies and regulates overall forex activities for compliance and efficient market functioning.&nbsp;

Another crucial role of the RBI here is to manage this foreign exchange reserve as the country’s custodian. Being a custodian of this, the RBI ensures that such a reserve can act as a financial buffer against external shocks and maintain stability in the Indian economy.&nbsp;

The RBI also acts as an exchange rate stabiliser as it plays an active role in maintaining the stability of the Indian Rupee. It is important as currency swings may weaken the rupee, which in turn increases import costs and contributes to rising inflation (if any) within the economy.&nbsp;

As a licensing authority, the RBI also allows commercial or co-operative banks which are equipped enough to deal with foreign exchange transactions in India.&nbsp;

How Does RBI Manage India's Foreign Exchange Reserves?

The Reserve Bank of India holds assets in foreign currencies to use them for payment for international obligations, especially in scenarios of crisis, to maintain the stability of the Indian currency.&nbsp;

It is one of the largest components of the forex reserves of India. Also known as FCA, it includes currencies like the US Dollar, the Euro, the Pound, the Yen, etc. Recently, FCA of India increased by $8.663 billion in valuation, touching an all-time high of $725.727. These are liquid assets so that the RBI can put them to use quickly in times of need.&nbsp;

As its name implies, it is the physical gold that the forex reserve of India stores domestically or across the border. Unlike the FCA, these are not that liquid, and they act as a hedging tool during currency fluctuation, inflation, etc.&nbsp;

Special Drawing Rights and IMF Reserve Tranche

Special Drawing Rights or SDRs are international forex reserve assets which the International Monetary Fund or IMF allocates to India. The IMF reserve tranche is simply an emergency account with the IMF, which its members, like India, can access without any conditions or fees in times of need.&nbsp;

How Does RBI Stabilise the Indian Rupee Exchange Rate?

India follows a managed floating exchange rate, where the nation’s currency value fluctuates based on market dynamics. Here is a detailed breakdown:&nbsp;

To smooth out excessive movement of currencies, the RBI buys foreign currencies when the rupee gets stronger against them. When the rupee becomes weak, and to prevent import cost inflation, it sells those foreign currencies. AD Category I entities typically execute these RBI interventions by buying and selling foreign currencies on the RBI’s behalf.

Interest rate decisions may indirectly impact the forex behaviour. For example, currently the interest rate is standing at a moderate <a href="https://data.rbi.org.in/#/dbie/home">5.25%</a>, and a higher interest rate may attract foreign capital. While a lower rate may fuel growth, it reduces inflow. With policy adjustments, the RBI aims to control inflation, even if currency pressures emerge.

With forward contracts, the RBI locks in an exchange rate today for a given date in future to deal with currency swings. While currency swaps allow the RBI to exchange currency at the present time, with an agreement to reverse the transaction later. These help the central bank to manage liquidity and keep a check on volatility without disrupting the market.

What is FEMA and How Does It Govern Forex Transactions?

As you know, to fulfil the role of RBI in foreign exchange market, the centralised bank follows the FEMA framework. Here is how FEMA governs foreign transactions:

As per the FEMA guidelines, current account transactions are usually permitted without requiring an RBI approval. These typically include payments regarding foreign trades, export/import payments, freelance income, etc.&nbsp;

It is the type of transaction that involves a change or alteration of assets and liabilities. It also considers liabilities which may occur in the future (e.g., a loan) held overseas by Indian residents. The RBI oversees and regulates such transactions and approves them.

The FEMA lays down provisions for civil penalties in case of violations. It also allows certain offences to style through compounding. However, violation of FEMA guidelines may go up to 3 times the amount for a certain contravention.&nbsp;

Worried about RBI compliance while making international payments? Skydo brings you RBI-compliant virtual accounts with multiple currency options, transparent fees and automated FIRC generation. Explore <a href="https://www.skydo.com/">Skydo's Global Bank Account</a> today!

How do RBI Forex Regulations Affect Indian Exporters and Freelancers?

Now that you know the role of RBI in foreign exchange market of India, if you are an Indian exporter or a freelancer, check how its regulation impacts payments, documentation, and FIRC here:&nbsp;&nbsp;

The RBI recently extended the realisation of export proceeds from the earlier 9-month timeframe to 15 months. Therefore, if you are in an export business, you must realise your proceeds within this timeframe, or else it may lead to compliance issues.&nbsp;

Whether you are an exporter or a freelancer, you must obtain a <a href="https://www.skydo.com/blog/all-you-need-to-know-about-firc-a-complete-guide">Foreign Inward Remittance Certificate (FIRC)</a> from your bank, which confirms a remittance in foreign currencies. An FIRC is important for GST refunds, tax filings and overall regulatory compliance.

It is a mandatory label which banks use to highlight why an entity or an individual is receiving money from overseas in India. For example, an inward <a href="https://www.skydo.com/blog/rbi_purpose_code_for_inward_remittance">purpose code</a> usually begins with ‘P’ and such transactions are usually payments for exports, salary, software services, gifts, investments, etc.&nbsp;

How Can Exporters Receive RBI-Compliant International Payments Easily?

Exporters can receive RBI-compliant international payments easily by choosing platforms that streamline collections while handling regulatory requirements end-to-end.

Here’s how solutions like Skydo help:&nbsp;&nbsp;

Focus on your freelance work or export business instead of stressing over complex forex paperwork with Skydo. Open a free account and<a href="https://www.skydo.com/"> </a>start enjoying RBI-compliant forex solutions with us!

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Air Import General Manifest (IGM) is a legal document filed with the Indian Customs for all goods arriving in India by air. It is submitted by the airline or its authorised agent (such as a ground handler), not the exporter or importer.

This requirement falls under Section 30 of the Customs Act, and its primary purpose is to inform Customs about the details of incoming cargo, including the consignor, consignee, and shipment information, before clearance begins.

An Air IGM contains a complete summary of cargo on a flight, including:

Customs uses this information to assess risk, identify restricted goods, and plan inspections.

Air IGM tracking is not just a routine check. It helps you identify issues early and take timely follow-up actions, which can support faster customs clearance.

A Bill of Entry can be filed in advance using shipment details such as the AWB number, even before the Air IGM is accepted on ICEGATE. However, it will not be processed or assessed until the IGM status shows “Accepted.” If the IGM is pending or has errors, the clearance process cannot move forward. Many importers constantly check the status of the ICEGATE bill of entry. They don’t realize that the problem actually lies with the IGM.&nbsp;

The longer your cargo remains stuck at the airport, the higher the cost added. You need to shell out demurrage charges, warehouse rent, and handling fees. Timely tracking allows you to follow up and reduce avoidable delays.&nbsp;

Even small mistakes can disrupt the process significantly. Here are some of the common errors:

Improves Visibility of the Supply Chain&nbsp;

Importers can combine Air IGM tracking with tools such as Bill of Entry status and cargo tracking updates to get a clearer view of their shipment cycle and take quicker corrective action when needed.&nbsp;

How to Track Air IGM Status on ICEGATE: A Step-by-Step Guide

When you know the details that are to be entered, tracking Air IGM on ICEGATE becomes a simple process. There’s no technical knowledge required. You must simply provide accurate data. Follow these steps to track the Air IGM status:

Visit the ICEGATE portal, navigate to ‘Services’, select ‘Enquiry’ and then the ‘Public Enquiries 2.0’. Now click on ‘Document status’ and select ‘Air IGM’

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Now, provide the necessary details to fill out the fields like location and AWB Number. Cross-check the details for accuracy, as even a small typo error will not show the results.

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Once you enter all the details, click submit. On the system, you will be able to see:

In case the shipment is part of a Consol, you may also see references to ICEGATE air consol data.

Cross-check the details with your Bill of Entry and make sure that the IGM status is accepted, your AWB is correctly linked, and no pending errors show up.&nbsp;

What are the Types of Air IGM Codes on ICEGATE?

Most of the time, confusion arises while understanding what status codes mean. On the portal, you can see short labels. However, each of these has a real implication for your shipment. Here is a simple breakdown that can help you:

What does “Error” Really Mean?

One of the most commonly misunderstood statuses is the “Error”. An error does not mean your shipment is rejected permanently. Some information might be missing or incorrect. Some of the common reasons are incorrect names of the consignee, a mismatch in the Airway Bill, a missing description of the cargo, or errors in data entry.

None of these errors can be fixed by yourself. The IGM has to be corrected and filed again by the airline or its agent.&nbsp;

Importers must note that there might be a difference between CGM-level statuses and master IGM statuses when consolidated cargo is shipped.

If your cargo is part of a consol shipment, you might see:

This means the master manifest is cleared, but your individual shipment is still being processed.&nbsp;

Air IGM vs Sea IGM: Similarities and Differences

The purpose of Air IGM and Sea IGM may be the same. However, there are differences in their processes and timelines. Have a look at how these two compare against each other.

If you export goods or services you must be familiar with the intricacies of receiving payments globally. This is where delays often occur with traditional banking systems due to intermediary charges, unclear FX rates, and slow settlement timelines.

Skydo simplifies this process by enabling exporters to receive <a href="https://www.skydo.com/blog/cross-border-payments">cross-border payments</a> with greater transparency and lower costs. The three key features that make Skydo a preferred choice for exporters are:

Therefore, <a href="https://www.skydo.com/">Skydo</a> serves as a practical solution for importers after tracking and clearing shipments. There’s no need to wait for long bank processes, as this platform helps to move your payment faster.

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Trade credit insurance helps businesses manage the financial risk of selling on credit by covering eligible losses when customers fail to settle their dues. The policy can protect against situations such as insolvency, default or extended payment delays, depending on its terms.

For exporters and service providers in India, this cover can be particularly useful when a significant portion of revenue depends on invoices from overseas customers. In case a buyer fails to pay, the resulting loss does not have to fall entirely on the business, provided that the situation is covered by the policy.

For example, say an information technology (IT) company in Bengaluru completes a $40,000 assignment for a customer based in the United Arab Emirates (UAE). If the customer becomes insolvent before clearing the invoice, the company may be able to recover the insured portion of the outstanding amount through its <a href="https://www.skydo.com/blog/what-is-trade-credit-meaning">trade credit</a> insurance policy.

How Does a Trade Credit Insurance Policy Work?

A <a href="https://www.skydo.com/blog/what-is-trade-credit">trade credit</a> insurance policy works by covering a business against eligible losses when an approved buyer does not pay its invoice. The insurer first assesses the buyer and sets a credit limit, after which the business can trade on credit within that limit. In case the buyer later defaults or becomes insolvent, the business can file a claim and receive the covered portion of the unpaid amount. Here is how it works:

The insurer may also continue monitoring the financial position of covered buyers. This credit information can help exporters decide whether to extend additional credit or adjust existing limits.

Because insured receivables carry less payment risk, they may also strengthen an exporter's case when applying for working capital. Lenders may be more comfortable financing receivables that have appropriate insurance cover, potentially supporting larger credit facilities.

What Does Trade Credit Insurance Actually Cover?

Trade credit insurance covers losses arising from a buyer's failure to pay for goods or services supplied on credit. Depending on the policy, the cover can include buyer insolvency, prolonged non-payment and certain political risks that prevent an overseas buyer from making the payment.

What Does Trade Credit Insurance NOT Cover?

Trade credit insurance does not cover every type of non-payment. Common exclusions include buyer-exporter disputes, losses resulting from the exporter's own contractual failures, transactions where payment was made in advance, certain political and force majeure risks and receivables that fall outside the policy's approved limits or conditions.

Who Sells Trade Credit Insurance in India?

Trade credit insurance in India is available from both public-sector and private insurers, including ECGC Limited, HDFC ERGO, Bajaj General Insurance, and New India Assurance. Their policies differ in terms of the type of receivables covered, buyer risk, eligibility and pricing.

Related: <a href="https://www.skydo.com/blog/red-clause-letter-of-credit">Red Clause Letter of Credit: How It Works &amp; Examples</a>

How Much Does Trade Credit Insurance Cost in India?

The cost of trade credit insurance in India depends on the size and risk of the receivables being insured. Insurers consider factors such as the total insured turnover, where the buyers are located, their creditworthiness, the payment terms offered and whether the policy covers commercial risk alone or includes political-risk protection.

Note: Do not compare trade credit insurance policies on premium alone. Check the buyer credit limits, exclusions, waiting periods, deductibles, political-risk coverage and percentage of loss actually indemnified before choosing a policy.

What Are the Types of Trade Credit Insurance?

The main types of trade credit insurance include whole-turnover, single-buyer, key-account and excess-of-loss cover. Note that each type of trade credit insurance suits a different level and pattern of buyer exposure.

Related: <a href="https://www.skydo.com/blog/pre-shipment-credit">Pre-Shipment Credit: Meaning, Types, Interest Rates &amp; How to Get It: Guide for Indian Exporters</a>

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A Foreign Inward Remittance Advice (FIRA) is bank credit advice recording an international payment received in India. It typically includes transaction details such as the amount, sender, exchange rate and purpose code; the exact fields depend on the bank and payment route.

<a href="https://www.skydo.com/blog/importance-of-fira-for-freelancers">Freelancers and service exporters keep it</a> with invoices and bank statements to document foreign client payments. It is a useful receipt for cross-border income, but it does not by itself establish every tax or export-compliance condition.

Say a Bengaluru-based UX designer invoices a UK client £1,500. Once the payment reaches her HDFC account, she keeps the bank's remittance advice with the invoice and account statement. Together, these records help her explain the payment during an audit.

A FIRA supports payment records for regulatory checks, Goods and Services Tax (GST) documentation, income tax audits, export-receipt reconciliation and enterprise or bank verification. The required evidence varies by purpose.

To obtain FIRA from HDFC, first distinguish a remittance advice from a disposal instruction. The instruction tells the bank how to process an incoming payment. HDFC supports online disposal instructions, but the advice-delivery route depends on your account and payment. Check your registered email for the credit advice, then use the relevant route below if you need help obtaining it.

Path A: Savings or Current Account (Freelancers and Retail Users)

Path B: MSME or Business Account (Exporters)

FIRA vs FIRC vs eBRC: What Is the Difference?

FIRA, Foreign Inward Remittance Certificate (FIRC), and Electronic Bank Realisation Certificate (<a href="https://www.skydo.com/blog/fira-vs-ebrc-amazon-global-sellers-india">eBRC</a>) serve different purposes. A FIRA records a payment. A FIRC is a bank-issued remittance certificate, not simply another name for every advice. An eBRC is generated on the Directorate General of Foreign Trade (DGFT) portal using bank-reported remittance information and export details. Generating one does not itself close an EDPMS entry.

A FIRA records an inward remittance and typically includes sender, amount, exchange-rate and purpose details. Banks may provide credit advice electronically. Do not assume that every bank automatically issues the same document or uses the same name for it.

Freelancers, IT consultants and service exporters use remittance advice for audits and bookkeeping, whether or not they apply for export benefits. The document needed for a particular application depends on its rules.

A FIRC is a formal bank certificate confirming an inward remittance. Banks distinguish this certificate from credit advice, even though the terms are sometimes used loosely.

Ask the bank which document applies to your transaction and intended use. Avoid assuming that every FIRC is restricted to investment receipts: GST refund rules still refer to FIRC or Bank Realisation Certificate evidence for export services.

An eBRC records export proceeds using bank-reported remittance information and the relevant export details. It can cover the amount realized against an export record; it does not necessarily mean that the entire invoice is paid or its EDPMS entry is closed.

The bank transmits an Inward Remittance Message (IRM) to DGFT. The exporter then self-certifies and generates the eBRC on the DGFT portal using the applicable export details. Follow the current portal requirements for your goods or services export.

Exporters use eBRCs where required for export benefits or other applications. Scheme eligibility and GST refund evidence have separate rules; an eBRC alone does not establish eligibility or close EDPMS.

How Does Skydo Help Receive International Payments?

Skydo automatically provides a free FIRA for each settled international payment, available from its dashboard without a separate request. A FIRA is not the same as a formal FIRC.

<a href="https://www.skydo.com/">Skydo</a> helps Indian freelancers and exporters receive international payments, with free FIRA documentation included as a standard feature rather than an add-on.