Navigate India's rigorous TP landscape. Ensure compliance with Section 92 of the Income Tax Act and manage documentation for both international and Specified Domestic Transactions (SDT).
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Transfer Pricing regulations in India were introduced in 2001. Overseen by the Central Board of Direct Taxes (CBDT), India follows the Arm's Length Principle (ALP) for international transactions and certain Specified Domestic Transactions.
India is known for active TP audits. With the adoption of BEPS Action 13, India has implemented a three-tier documentation structure, including Master File and Country-by-Country Reporting, alongside local Accountant’s Reports (Form 3CEB).
The core statutory provisions of the Income Tax Act, 1961, governing the computation of income from international transactions.
Specifies the methods for determining the Arm's Length Price and the detailed documentation requirements (Rule 10D).
Provides a simplified compliance route for certain sectors (e.g., IT/ITES) where the tax authority accepts declared prices.
Mandatory certification for all covered transactions.
Every person entering into an international transaction or SDT must obtain a report from a Chartered Accountant in Form No. 3CEB.
The report must be filed electronically on or before October 31st of the relevant assessment year.
Threshold-based reporting for MNEs in India.
Local File: Mandatory for transactions exceeding INR 1 Crore (Rule 10D).
Master File: Required for MNE groups with consolidated revenue over INR 500 Crore and Indian entity transactions over INR 50 Crore (or INR 10 Crore for intangibles).
Reporting for groups with revenue over INR 6400 Crore.
MNE groups headquartered in India with a consolidated revenue exceeding INR 6,400 Crore (approx. EUR 750M) must file Form 3CEAD.
The report is due within 12 months from the end of the reporting accounting year.
Full support for certification and e-filing compliance.
Assistance with Advance Pricing Agreements and Mutual Agreement Procedures.
Representing clients before the TPO and ITAT authorities.
Managing compliance for Specified Domestic Transactions.
Navigate India's complex TP landscape with our specialized local expertise and benchmarking solutions.
Contact India TeamFor further information on transfer pricing please contact:
Principal
Leader - TP Policy