Transfer Pricing Services in India
End-to-End TP Compliance -- Documentation, Benchmarking, Form 3CEB, APA and Litigation Support
Transfer pricing (TP) compliance in India is an annual, multi-step obligation for any taxpayer with international transactions with associated enterprises (AEs) exceeding Rs 1 crore. It covers preparation of TP documentation (Local File and Master File), benchmarking analysis to determine the arm's length price, Form 3CEB certification by a Chartered Accountant, and filing with the income tax return. When the Assessing Officer (AO) or Transfer Pricing Officer (TPO) raises a TP adjustment, the taxpayer must defend through the dispute resolution process -- DRP or ITAT. Our end-to-end transfer pricing services cover every stage of this lifecycle -- from policy design and annual documentation through assessment defence and APA applications.
Our Transfer Pricing Services
TP Documentation (Local File)
Preparation of the Local File -- entity overview, industry analysis, description of international transactions, functional analysis (FAR), comparables selection, benchmarking, and ALP determination for each transaction category.
Master File
Preparation of the Master File for Indian constituent entities of MNE groups with consolidated group revenue above Rs 500 crore -- covering group structure, business description, intangibles, intercompany flows, and financial/tax positions.
Form 3CEB Certification
CA-certified Form 3CEB report covering all international transactions and SDTs -- mandatory for all taxpayers with aggregate international transactions exceeding Rs 1 crore, filed before the ITR due date.
Benchmarking Analysis
Selection of the most appropriate TP method (CUP, RPM, CPM, PSM, TNMM), comparables search using TP databases, filtering, and margin/price range computation for arm's length determination. See our dedicated benchmarking page.
APA Applications
Advisory and filing of Advance Pricing Agreement (APA) applications -- unilateral, bilateral, or multilateral -- to obtain CBDT certainty on arm's length price for covered transactions for future years.
TP Litigation Support
Representation before the TPO in TP proceedings, drafting of DRP objections, and ITAT appeals -- providing robust arm's length defence with comparables analysis and functional evidence.
Transfer Pricing Compliance Deadlines
| Activity | When Required | Consequence of Non-Compliance |
|---|---|---|
| TP Documentation (Local File) | Maintained by the ITR due date; submitted within 30 days of TPO requisition | Penalty of 2% of transaction value under Section 271AA |
| Master File (Form 3CEAA) | Filed with Designated Authority by ITR due date | Penalty of Rs 5 lakh for failure to furnish |
| Form 3CEB | Filed with ITR (October 31 / November 30) | Penalty of Rs 1 lakh under Section 271BA |
| CbCR (Form 3CEAC) | Within 12 months of end of reporting accounting year | Rs 5,000 to Rs 50,000 per day of delay |
Frequently Asked Questions
Who needs to maintain TP documentation in India?
What is Form 3CEB and when must it be filed?
What is the Safe Harbour option in Indian transfer pricing?
Need Complete Transfer Pricing Compliance? Our TP Team Handles Everything.
TP documentation, Form 3CEB, benchmarking, Master File, APA applications, and litigation support -- all under one roof.
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