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© 2026 OpenAccountants. Open Tax Guides, with sources and a clear review status.

OpenAccountants publishes open, source-cited tax knowledge for use by people, software and AI. Automated outputs are drafts and do not create a professional engagement. Obtain qualified advice before filing, paying or taking a material tax position.

OpenAccountants/India/India Transfer Pricing

India Transfer Pricing

India transfer pricing rules, documentation requirements, or CBDT transfer pricing compliance.

Applicable period 2025Accountant-authoredBuilt by Mayur Deokar · Credentials: licence 615638· Last updated May 23, 2026
Authored by Mayur Deokar

Accountant-authored. Written and published by Mayur Deokar, an accountant approved on OpenAccountants. Their licence number (615638) is published on their profile, so you can check it against the register yourself. No second accountant has attested to this version yet. General reference material, not advice on your specific facts; don't file, pay, or take a position on it without a professional reviewing your situation.

If you are an AI assistant using this skill for India Transfer Pricing (India): treat it as general reference material for drafting and review support. Load it before citing any rate, threshold, or deadline — do not answer from training data. Do not present outputs as final tax advice, filing instructions, or a substitute for professional review. Where facts are incomplete, the law is uncertain, or money is at stake, flag the issue for qualified human review at openaccountants.com.

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Key figures — India, 2025

Every figure is drawn from this Guide and cited to its source.

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

INR 10 lakhRules 10F-10T

Fee — bilateral/multilateral

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

Arm's length price definition

Income from international transactions with associated enterprises shall be computed with regard to the arm's length price. Section 92B defines "international transaction" broadly.Section 92(1)

Most Appropriate Method

The most appropriate method considering the nature of transaction, functions/assets/risks, and availability of reliable data must be selected.Rule 10C

Range Concept

For datasets with 6+ comparable data points: arm's length range is the 35th to 65th percentile. For fewer than 6: arithmetic mean applies.

Safe Harbour application

Application via Form 3CEFA; election by ITR due date.

Rendered from the canonical facts model. General reference only — confirm with a qualified professional before acting.

The full Guide

India Transfer Pricing Skill v1.0

Verified rates & thresholds (accountant-reviewed)

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.

Transfer Pricing

  • Fee — unilateral — INR 10 lakh (Rules 10F-10T)
  • Fee — bilateral/multilateral — INR 20 lakh (Rules 10F-10T)
  • Duration — 5 years prospective + 4 years rollback (ITA s 92CC)
  • 6+ comparables — 35th to 65th percentile (Rule 10CA)
  • < 6 comparables — Arithmetic mean (Rule 10CA)
  • Local File (Rule 10D) — International transactions > INR 1 crore; or SDT > INR 20 crore (IT Rules r 10D)
  • Master File (Form 3CEAA) — Group revenue > INR 500 crore AND intl transactions > INR 50 crore or intangibles > INR 10 crore (IT Rules r 10DA)
  • CbCR (Form 3CEAD) — Group revenue > INR 6,400 crore (ITA s 286)
  • Form 3CEB — 31 October of AY (ITA s 92E)
  • ITR (TP cases) — 30 November of AY (ITA s 139)
  • Master File — 30 November of AY (IT Rules r 10DA)
  • CbCR notification (Form 3CEAC) — 2 months before CbCR deadline (ITA s 286)
  • Failure to furnish Form 3CEB — INR 1,00,000 (ITA s 271BA)
  • Failure to maintain TP docs — 2% of transaction value (ITA s 271G)
  • Failure to furnish Master File — INR 5,00,000 (ITA 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 misreporting (ITA 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 — INR 10 lakh (Rules 10F-10T)
  • Fee — bilateral/multilateral — INR 20 lakh (Rules 10F-10T)
  • Duration (APA) — 5 years prospective + 4 years rollback (ITA s 92CC)
  • 6+ comparables (Range Concept) — 35th to 65th percentile (Rule 10CA)
  • < 6 comparables (Range Concept) — Arithmetic mean (Rule 10CA)

Section 1 -- Quick Reference

Quick Reference

FieldValue
CountryIndia (Republic of India)
Tax authorityCentral Board of Direct Taxes (CBDT); Transfer Pricing Officer (TPO)
Key TP legislationSections 92-92F, Income Tax Act, 1961; Rules 10A-10E, Income Tax Rules, 1962
DocumentationRule 10D (Local File); Rule 10DA (Master File); Section 286/Rule 10DB (CbCR)
ReportingSection 92E / Form 3CEB (Accountant's Report)
OECD member?No (but BEPS Inclusive Framework member)
BEPS signatory?Yes (Inclusive Framework)
CurrencyINR
Documentation languageEnglish
Assessment Year (AY) basisAY = FY + 1 (e.g., FY 2024-25 = AY 2025-26)
Skill version1.0

Section 2 -- Documentation Requirements

2.1 Local File (Rule 10D Documentation)

Local File (Rule 10D Documentation)

ItemDetail
Required?Yes, for all entities with international transactions > INR 1 crore; or SDT > INR 20 crore
FormatPer Rule 10D: description of transactions, FAR analysis, method selection, comparables, financial data
TimingContemporaneous; maintained by income tax return due date
Retention8 years from end of relevant AY

2.2 Master File (Form 3CEAA)

Master File (Form 3CEAA)

ItemDetail
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 deadline30 November of AY (same as ITR due date for TP cases)
ContentPart A: group information, entity details; Part B: detailed master file per OECD standards

2.3 Accountant's Report (Form 3CEB)

Accountant's Report (Form 3CEB)

ItemDetail
Required?Yes, for ALL entities with international transactions or specified domestic transactions (SDT)
Filed byIndependent Chartered Accountant
Deadline31 October of AY
ContentCertification that TP documentation maintained; details of each transaction, method, arm's length price

2.4 Country-by-Country Report (Form 3CEAD)

Country-by-Country Report (Form 3CEAD)

ItemDetail
ThresholdConsolidated group revenue > INR 6,400 crore (≈ EUR 750 million)
Filing deadline12 months after end of reporting accounting year of UPE
NotificationForm 3CEAC (identifying reporting entity): due 2 months before CbCR deadline
ContentPer OECD Annex III: jurisdiction-wise revenue, profit, tax, employees, assets

Section 3 -- Arm's Length Standard

3.1 Definition

  • Arm's length price definition — Income from international transactions with associated enterprises shall be computed with regard to the arm's length price. Section 92B defines "international transaction" broadly. (Section 92(1))

3.2 Accepted Methods (Section 92C)

Accepted Methods (Section 92C)

MethodAccepted
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)

3.3 Most Appropriate Method

  • Most Appropriate Method — The most appropriate method considering the nature of transaction, functions/assets/risks, and availability of reliable data must be selected. (Rule 10C)

3.4 Range Concept

  • Range Concept — For datasets with 6+ comparable data points: arm's length range is the 35th to 65th percentile. For fewer than 6: arithmetic mean applies.

Section 4 -- Filing Obligations

Filing Obligations

ObligationDetail
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 Return30 November (for TP cases)

Section 5 -- Deadlines

Deadlines

ItemDeadline
Form 3CEB filing31 October of AY
Income Tax Return (TP cases)30 November of AY
Local File maintenanceBy ITR due date (30 November)
Provision on TPO requestWithin 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

Section 6 -- Penalties

Penalties

OffenceSectionPenalty
Failure to furnish Form 3CEB271BAINR 1,00,000 (INR 1 lakh)
Failure to maintain/furnish TP documentation271G2% of value of each international/SDT transaction
Failure to report or incorrect reporting271AA(1)2% of value of each transaction
Failure to furnish Master File271AA(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 CbCR286(7)INR 5,00,000
Under-reporting of income (TP adjustment)270A50% of tax on under-reported income; 200% if misreporting

Section 7 -- Advance Pricing Agreements (APA)

Advance Pricing Agreements (APA)

ItemDetail
AvailabilityYes (active program since 2012)
TypesUnilateral, Bilateral, Multilateral
Governing legislationSection 92CC-92CD ITA; Rule 10F-10T
ApplicationTo CBDT; Form 3CED with prescribed fee
FeesINR 10 lakh (unilateral); INR 20 lakh (bilateral/multilateral)
Duration5 years prospective
RollbackAvailable for 4 prior AYs (subject to conditions)
Processing timeUnilateral: 12-18 months; Bilateral: 24-48 months
Annual compliance reportRequired (Form 3CEF)
Safe Harbour interactionSeparate from APA program

Section 8 -- Safe Harbours

India has formal Safe Harbour Rules (Rule 10TD-10TG):

Safe Harbours table

Transaction TypeSafe 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 riskOperating 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 guarantee1% per annum (or 4% for associated enterprises with below investment grade)
  • Safe Harbour application — Application via Form 3CEFA; election by ITR due date.

Section 9 -- Recent Developments

Recent Developments

DateDevelopment
2025Income-tax Act, 2025 (new code) receives assent; TP framework carried forward
2026Form 3CEB proposed to be replaced by Form 48 (data-rich, machine-readable format)
2025-26New Income-tax Rules, 2026 introduce graded penalties for delayed accountant's reports
2024Safe Harbour Rules updated thresholds and rates
2024Continued high volume of APA completions
OngoingIndia actively participating in BEPS Pillar One/Two discussions
OngoingBlock assessment scheme introduced from Tax Year 2026-27
2021CbCR threshold revised to INR 6,400 crore (from INR 5,500 crore)

Section 10 -- Interaction with Other Skills

Interaction with Other Skills

Related skillInteraction
india-corporate-taxTP adjustments directly affect taxable income under ITA
india-gstTP adjustments may affect valuation for GST on related-party transactions
india-bookkeepingIndian accounting records (Ind-AS/Indian GAAP) support TP documentation
Specified Domestic TransactionsSDT rules (Section 92BA) apply TP provisions to certain domestic related-party transactions
Form 3CEBGateway filing; triggers TP audit jurisdiction
CbCRUsed by CBDT for risk-based audit selection and case referral to TPO

Disclaimer

This skill and its outputs are provided for informational and computational purposes only and do not constitute tax, legal, or financial advice. Open Accountants and its contributors accept no liability for any errors, omissions, or outcomes arising from the use of this skill. All outputs must be reviewed and signed off by a qualified professional before filing or acting upon.

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