VCH supports clients in aligning pricing models across jurisdictions while maintaining coherence with Indian transfer pricing law and FEMA requirements
Harinath Chitturi, Founder & Partner
India’s transfer pricing landscape is operating in a more refined framework, driven by domestic reforms and deeper global integration. Strengthening economic ties with the United States and trade arrangements with the EU, UK, Gulf Cooperation Council and New Zealand are increasing the scale and complexity of inter-company transactions, particularly across technology, manufacturing, digital services and Global Capability Centres.
Simultaneously, AI-led operating models are compressing margins and intensifying audit scrutiny on profit allocation. These pressures are further amplified by the implementation of the OECD’s BEPS Pillar Two global minimum tax regime, which has heightened sensitivity around effective tax rates, profit alignment and defensible pricing outcomes.
While the recent proposal to rationalise Indian safe harbour margins offers limited relief, it is not universally applicable, especially for low-margin businesses. Against this backdrop, transfer pricing has evolved from a compliance exercise into a strategic, risk-critical function one around which VCH & Associates LLP (‘the Firm’ or ‘VCH’ or ‘VCH & Associates’) has built its practice, grounded in the principle that defensible pricing should be tax-efficient and established before scrutiny begins, not after it arrives.
As a specialized professional services firm, VCH & Associates focuses on transfer pricing and related cross-border taxation and regulatory advisory. It advises multinational enterprises, foreign-owned Indian subsidiaries and Indian companies engaged in inter-company transactions on transfer pricing policy and documentation, audit defense and litigation support, Advance Pricing Agreements (APAs), international tax matters and advisory and compliance under the Foreign Exchange Management Act (FEMA).
The firm integrates transfer pricing with FEMA services to align pricing policies, inter-company contracts and exchange control reporting. Further, VCH also supports advisory firms and chartered accountants in handling their clients’ complex transfer pricing compliance and litigation matters, along with FEMA advisory. “We are keenly aware of how multinational enterprises perceive India’s transfer pricing litigation and regulatory environment. Accordingly, we ensure that tax-efficient transfer pricing policies are framed to reflect the actual substance of transactions and that inter-company agreements, FEMA approvals and related regulatory reporting are structured cohesively to minimise execution risk and downstream disputes,” says Harinath Chitturi, Founder & Partner at VCH & Associates.
Beyond Documentation
Adopting a risk-first advisory model, the Firm does not treat transfer pricing as a year-end compliance deliverable. It constructs positions grounded in economic substance, industry-specific benchmarking and transaction-level analysis. During assessments, it identifies exposure early, discusses margin variations with management and reframes submissions before positions harden.
It works closely with multinational groups that operate through layered supply chains and shared service arrangements and require structured defense during scrutiny proceedings. VCH represents foreign-owned Indian subsidiaries that face detailed examinations of their functional profile and margin positions during assessments. The Firm advises Indian companies that engage in outbound transactions and need support in defending pricing models before tax authorities and appellate forums.
Its involvement in Advance Pricing Agreement engagements includes strategic evaluation of suitability, handholding during the site visits, preparation of submissions and sustained representation through negotiation stages. The Firm also advises on cross-border restructuring exercises where pricing consequences must align with regulatory approvals and commercial substance. Beyond direct client mandates, the Firm provides technical support to Chartered Accountants and independent advisory firms that encounter specialised transfer pricing questions in their own engagements. It assists these professionals in framing tax efficient transfer pricing policy, benchmarking disputes, secondary adjustments and FEMA compliance overlaps that require focused expertise.
Cross-Border Coherence
Practical exposure to the United Arab Emirates adds another layer. The introduction of corporate tax and transfer pricing regulations in the UAE has prompted reassessment of regional headquarters models, intra-group services and India-Middle East structures. VCH supports clients in aligning pricing models across jurisdictions while maintaining coherence with Indian transfer pricing law and FEMA requirements. For businesses that operate through Dubai or other Gulf hubs, this cross-jurisdictional consistency mitigates regulatory asymmetry.
Technology Informs Delivery
In late 2025, the Firm initiated development of technology-enabled transfer pricing tools designed to enhance analytical rigour and consistency in documentation and risk assessment. Structured data workflows improve benchmarking precision. Standardised review protocols reduce variability in functional analysis. For clients, this translates into documentation that reflects data integrity rather than narrative adjustment.
VCH supports clients in aligning pricing models across jurisdictions while maintaining coherence with Indian transfer pricing law and FEMA requirementsHarinath Chitturi, Founder & Partner
The partner-led execution model shapes engagement outcomes. Harinath Chitturi, who leads the Firm’s transfer pricing, FEMA and international taxation practice, brings experience from large consulting environments, including exposure to APA support and complex litigation. Under his leadership, matters receive senior attention from strategy design through appellate proceedings.
Client Continuity and Measured Expansion
Engagements extend beyond Hyderabad into South India and international markets that include the U.K, the U.S., Australia and Dubai. The expansion reflects demand for specialist advisory that integrates compliance, regulatory alignment and dispute strategy.
Clients engage the firm as an extension of their tax function. Finance heads and global tax teams seek responsiveness, technical clarity and ownership of outcomes. In a regulation-intensive domain, credibility depends on precision. VCH frames its mission as delivering outcome-driven advisory that supports sustainable growth and regulatory confidence with a vision to build a specialist practice defined by technical excellence and practical insight.
For potential clients, the relevance lies in cause and effect. When pricing policies align with actual conduct and regulatory filings, audit exposure narrows. When benchmarking reflects transaction-specific economics rather than generic comparables, margin defense strengthens. When transfer pricing integrates with FEMA and international tax advisory, structural inconsistencies decline. The cumulative effect is not mere compliance but risk containment. VCH can deliver solutions that are technically robust, defensible and sustainable over the long term.
