Asked about India transfer pricing rules, documentation requirements, or CBDT transfer pricing compliance.
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Accountant-reviewed. Reviewed by Mayur Deokar (615638) on Jun 6, 2026. Review does not create a client relationship and is not a guarantee for any specific taxpayer or transaction.
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Fee — unilateral
INR 10 lakhRules 10F-10T
Fee — bilateral/multilateral
INR 20 lakhRules 10F-10T
Duration
5 years prospective + 4 years rollbackITA s 92CC
6+ comparables
35th to 65th percentileRule 10CA
< 6 comparables
Arithmetic meanRule 10CA
Local File (Rule 10D)
International transactions > INR 1 crore; or SDT > INR 20 croreIT Rules r 10D
Master File (Form 3CEAA)
Group revenue > INR 500 crore AND intl transactions > INR 50 crore or intangibles > INR 10 croreIT Rules r 10DA
CbCR (Form 3CEAD)
Group revenue > INR 6,400 croreITA s 286
Form 3CEB
31 October of AYITA s 92E
ITR (TP cases)
30 November of AYITA s 139
Master File
30 November of AYIT Rules r 10DA
CbCR notification (Form 3CEAC)
2 months before CbCR deadlineITA s 286
Failure to furnish Form 3CEB
INR 1,00,000ITA s 271BA
Failure to maintain TP docs
2% of transaction valueITA s 271G
Failure to furnish Master File
INR 5,00,000ITA s 271AA(2)
CbCR failure
₹5,000/day (1 mo); ₹15,000/day (beyond); ₹50,000/day (after order)ITA s 286(6)
Under-reporting (TP adjustment)
50% of tax; 200% if misreportingITA s 270A
IT/ITeS (≤ ₹200 Cr turnover)
OP/OC ≥ 17%Rule 10TD
IT/ITeS (> ₹200 Cr)
OP/OC ≥ 18%Rule 10TD
Contract R&D
OP/OC ≥ 24%Rule 10TD
Manufacturing (insignificant risk)
OP/OC ≥ 12%Rule 10TD
Corporate guarantee
1% p.a. (4% below investment grade)Rule 10TD
Fee — unilateral (APA)
INR 10 lakhRules 10F-10T
Fee — bilateral/multilateral (APA)
INR 20 lakhRules 10F-10T
Duration (APA)
5 years prospective + 4 years rollbackITA s 92CC
6+ comparables (Range Concept)
35th to 65th percentileRule 10CA
< 6 comparables (Range Concept)
Arithmetic meanRule 10CA
Reviewed against the cited tax authorities by Mayur Deokar on 2026-06-06.
Items flagged for further clarification are tracked separately and excluded here.
This block is generated from verified skill_facts — edit the facts, not the prose.
Quick Reference
| Field | Value |
|---|---|
| Country | India (Republic of India) |
| Tax authority | Central Board of Direct Taxes (CBDT); Transfer Pricing Officer (TPO) |
| Key TP legislation | Sections 92-92F, Income Tax Act, 1961; Rules 10A-10E, Income Tax Rules, 1962 |
| Documentation | Rule 10D (Local File); Rule 10DA (Master File); Section 286/Rule 10DB (CbCR) |
| Reporting | Section 92E / Form 3CEB (Accountant's Report) |
| OECD member? | No (but BEPS Inclusive Framework member) |
| BEPS signatory? | Yes (Inclusive Framework) |
| Currency | INR |
| Documentation language | English |
| Assessment Year (AY) basis | AY = FY + 1 (e.g., FY 2024-25 = AY 2025-26) |
| Skill version | 1.0 |
Local File (Rule 10D Documentation)
| Item | Detail |
|---|---|
| Required? | Yes, for all entities with international transactions > INR 1 crore; or SDT > INR 20 crore |
| Format | Per Rule 10D: description of transactions, FAR analysis, method selection, comparables, financial data |
| Timing | Contemporaneous; maintained by income tax return due date |
| Retention | 8 years from end of relevant AY |
Master File (Form 3CEAA)
| Item | Detail |
|---|---|
| Required? | Yes, if: (a) consolidated group revenue > INR 500 crore AND (b) aggregate international transactions > INR 50 crore OR intangible transactions > INR 10 crore |
| Filing deadline | 30 November of AY (same as ITR due date for TP cases) |
| Content | Part A: group information, entity details; Part B: detailed master file per OECD standards |
Accountant's Report (Form 3CEB)
| Item | Detail |
|---|---|
| Required? | Yes, for ALL entities with international transactions or specified domestic transactions (SDT) |
| Filed by | Independent Chartered Accountant |
| Deadline | 31 October of AY |
| Content | Certification that TP documentation maintained; details of each transaction, method, arm's length price |
Country-by-Country Report (Form 3CEAD)
| Item | Detail |
|---|---|
| Threshold | Consolidated group revenue > INR 6,400 crore (≈ EUR 750 million) |
| Filing deadline | 12 months after end of reporting accounting year of UPE |
| Notification | Form 3CEAC (identifying reporting entity): due 2 months before CbCR deadline |
| Content | Per OECD Annex III: jurisdiction-wise revenue, profit, tax, employees, assets |
Accepted Methods (Section 92C)
| Method | Accepted |
|---|---|
| Comparable Uncontrolled Price (CUP) | Yes |
| Resale Price Method (RPM) | Yes |
| Cost Plus Method (CPM) | Yes |
| Transactional Net Margin Method (TNMM) | Yes |
| Profit Split Method (PSM) | Yes |
| "Other Method" (including DCF) | Yes (sixth method, any method yielding most reliable result) |
Filing Obligations
| Obligation | Detail |
|---|---|
| Form 3CEB (Accountant's Report) | Annual electronic filing; 31 October |
| Local File (Rule 10D) | Maintain; provide within 30 days of request |
| Master File (Form 3CEAA) | Annual electronic filing; 30 November |
| CbCR notification (Form 3CEAC) | Annual; 2 months before CbCR deadline |
| CbCR (Form 3CEAD) | Annual; 12 months after UPE's year-end |
| Income Tax Return | 30 November (for TP cases) |
Deadlines
| Item | Deadline |
|---|---|
| Form 3CEB filing | 31 October of AY |
| Income Tax Return (TP cases) | 30 November of AY |
| Local File maintenance | By ITR due date (30 November) |
| Provision on TPO request | Within 30 days |
| Master File (Form 3CEAA) | 30 November of AY |
| CbCR notification (Form 3CEAC) | 2 months before CbCR due date |
| CbCR (Form 3CEAD) | 12 months after end of UPE's reporting year |
Penalties
| Offence | Section | Penalty |
|---|---|---|
| Failure to furnish Form 3CEB | 271BA | INR 1,00,000 (INR 1 lakh) |
| Failure to maintain/furnish TP documentation | 271G | 2% of value of each international/SDT transaction |
| Failure to report or incorrect reporting | 271AA(1) | 2% of value of each transaction |
| Failure to furnish Master File | 271AA(2) | INR 5,00,000 (INR 5 lakh) |
| Failure to furnish CbCR (Form 3CEAD) | 286(6) | INR 5,000/day (up to 1 month); INR 15,000/day beyond 1 month; INR 50,000/day after penalty order |
| Inaccurate CbCR | 286(7) | INR 5,00,000 |
| Under-reporting of income (TP adjustment) | 270A | 50% of tax on under-reported income; 200% if misreporting |
Advance Pricing Agreements (APA)
| Item | Detail |
|---|---|
| Availability | Yes (active program since 2012) |
| Types | Unilateral, Bilateral, Multilateral |
| Governing legislation | Section 92CC-92CD ITA; Rule 10F-10T |
| Application | To CBDT; Form 3CED with prescribed fee |
| Fees | INR 10 lakh (unilateral); INR 20 lakh (bilateral/multilateral) |
| Duration | 5 years prospective |
| Rollback | Available for 4 prior AYs (subject to conditions) |
| Processing time | Unilateral: 12-18 months; Bilateral: 24-48 months |
| Annual compliance report | Required (Form 3CEF) |
| Safe Harbour interaction | Separate from APA program |
India has formal Safe Harbour Rules (Rule 10TD-10TG):
Safe Harbours table
| Transaction Type | Safe Harbour Margin/Rate |
|---|---|
| IT/ITeS services (turnover ≤ INR 200 crore) | Operating profit/operating cost ≥ 17% (to AE) or 17% (non-AE) |
| IT/ITeS services (turnover > INR 200 crore) | Operating profit/operating cost ≥ 18% |
| KPO services (turnover ≤ INR 200 crore) | Operating profit/operating cost ≥ 18% |
| KPO services (turnover > INR 200 crore) | Operating profit/operating cost ≥ 18% |
| Contract R&D (wholly/partly) | Operating profit/operating cost ≥ 24% |
| Manufacturing with insignificant risk | Operating profit/operating cost ≥ 12% |
| Intra-group loans (INR) | 1-year MCLR + 175 bps (capped at INR 100 crore) |
| Intra-group loans (Foreign currency) | 6-month SOFR + relevant spread |
| Corporate guarantee | 1% per annum (or 4% for associated enterprises with below investment grade) |
Recent Developments
| Date | Development |
|---|---|
| 2025 | Income-tax Act, 2025 (new code) receives assent; TP framework carried forward |
| 2026 | Form 3CEB proposed to be replaced by Form 48 (data-rich, machine-readable format) |
| 2025-26 | New Income-tax Rules, 2026 introduce graded penalties for delayed accountant's reports |
| 2024 | Safe Harbour Rules updated thresholds and rates |
| 2024 | Continued high volume of APA completions |
| Ongoing | India actively participating in BEPS Pillar One/Two discussions |
| Ongoing | Block assessment scheme introduced from Tax Year 2026-27 |
| 2021 | CbCR threshold revised to INR 6,400 crore (from INR 5,500 crore) |
Interaction with Other Skills
| Related skill | Interaction |
|---|---|
| india-corporate-tax | TP adjustments directly affect taxable income under ITA |
| india-gst | TP adjustments may affect valuation for GST on related-party transactions |
| india-bookkeeping | Indian accounting records (Ind-AS/Indian GAAP) support TP documentation |
| Specified Domestic Transactions | SDT rules (Section 92BA) apply TP provisions to certain domestic related-party transactions |
| Form 3CEB | Gateway filing; triggers TP audit jurisdiction |
| CbCR | Used by CBDT for risk-based audit selection and case referral to TPO |
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Review status
Accountant-reviewed
Reviewed by a named licensed practitioner against the stated sources, as general reference material.
Accountant-reviewed · Guide version 10
Reviewed by Mayur Deokar · 6 June 2026
A named accountant reviewed this complete Guide version within the stated scope. It is not a guarantee.
View review record →Other India computations in the OpenAccountants Tax Library.
Rendered from the facts database · facts last reviewed Jun 6, 2026. General reference only — confirm with a qualified professional before acting.
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