Cross-border transaction documentation gaps.
Transfer Pricing
Transfer Pricing Advisory & Form 3CEB
Transfer pricing is the set of Indian income tax rules that require cross-border (and specified domestic) transactions between associated enterprises to be priced at arm's length. We help Indian subsidiaries, foreign-owned entities and outbound groups document those transactions under Rule 10D, file Form 3CEB by 31 October, and use Advance Pricing Agreements or safe harbour where it makes sense. Key takeaways: five prescribed methods (CUP, RPM, CPM, PSM, TNMM); Rule 10D contemporaneous documentation; Form 3CEB due 31 October; APA and safe harbour available to reduce dispute.
What's Included
Functional, Asset and Risk (FAR) analysis of every related-party transaction
Selection and justification of the most appropriate method from the five prescribed methods
Benchmarking study using Indian and global databases
Rule 10D contemporaneous documentation — Local File and Master File where applicable
Form 3CEB — accountant's report by 31 October
Country-by-Country Reporting (CbCR) support for in-scope MNE groups
Advance Pricing Agreement (APA) and safe-harbour evaluation and filing
Representation before the Transfer Pricing Officer (TPO) and DRP
Our Process
STEP 1
Scoping
Map associated enterprises, related-party transactions and applicability of TP and SDT rules.
Week 1
STEP 2
FAR analysis
Document functions performed, assets used and risks assumed by each entity.
Week 1–2
STEP 3
Method & benchmarking
Select the most appropriate method and run the comparables search.
Week 2–4
STEP 4
Documentation
Prepare Local File / Master File / CbCR notifications under Rule 10D.
Week 4–5
STEP 5
Form 3CEB & filing
Issue Form 3CEB and file with the income tax return by 31 October.
By 31 October
Documents Required
- Group structure chart and shareholding pattern
- Inter-company agreements for goods, services, royalties, loans and guarantees
- Financial statements of the Indian entity and key overseas counterparties
- Transaction-level invoices, ledgers and pricing policy notes
- Existing transfer pricing study, if any, and prior assessment orders
Key Statutory References
| Item | Reference |
|---|---|
| Income Tax Act, 1961 | Sections 92 to 92F — arm's length, methods, documentation and 3CEB |
| Income Tax Rules | Rule 10D — contemporaneous documentation; Rule 10DA / 10DB — Master File and CbCR |
| Form 3CEB | Accountant's report — due 31 October |
| Dispute avoidance | APA (unilateral / bilateral / multilateral) and safe harbour rules |
Frequently Asked Questions
Related Services
Guides & Resources
Overseas investment rules affecting transfer pricing.
Document the arm's-length position before the next 3CEB cycle
Book a free 15-minute advisory call with Regi Tom Antony.