Transfer Pricing · Section 92–92F · Form 3CEB · India
Transfer Pricing Compliance for Indian Companies
From the first rupee of any international related-party transaction, Section 92 applies. We handle the documentation, the accountant's report, the Master File, and the audit defence — so your CFO can focus on the deal, not the deadline.
What is Transfer Pricing?
Any transaction between "associated enterprises" (defined in Section 92A — 13 deeming tests including equity ≥26%, loans ≥51% of book-value of assets, guarantee ≥10% of borrowings, ≥50% board appointment) must be priced at "arm's length" under Section 92.
The six methods — CUP, RPM, CPM, PSM, TNMM, and the "Other Method" under Rule 10AB — are applied against the arm's length range: 35th–65th percentile (Rule 10CA) when ≥6 comparables, else arithmetic mean ±3%.
TP Applicability Funnel
Answer three questions to see which compliance layers apply to your company.
Does your company have any transaction with a related party outside India?
What is your company type?
What is your consolidated group revenue (all entities, globally)?
International transaction with an AE
Section 92 / Form 3CEB — If aggregate > ₹1 crore, Rule 10D documentation required.
Specified Domestic Transaction (SDT)
Section 92BA — Aggregate value > ₹20 crore. Post-Finance Act 2017 scope: only 80A / 80-IA(8)/(10) / 10AA transactions survive.
Safe Harbour eligible
Rule 10TD — Software development, ITES, KPO, contract R&D, auto components (incl. lithium-ion batteries — Notification 21/2025). Threshold ₹300 crore.
Master File obligated
Rule 10DA — Consolidated group revenue > ₹500 crore AND Indian entity international transactions > ₹50 crore OR IP transactions > ₹10 crore. Forms: 3CEAA (Part B) + 3CEAB.
CbCR obligated
Rule 10DB / Section 286 — Consolidated group revenue > ₹6,400 crore (Notification 88/2018). Forms: 3CEAC + 3CEAD + 3CEAE.
TP Diagnostic
Three questions, deterministic output. No server calls.
What is your company's primary cross-border transaction?
What is your aggregate value of international transactions per year?
Have you filed Form 3CEB before?
Free Transfer Pricing Tools
Associated Enterprise Check
Run the 13 deeming tests under Section 92A. Tells you if two entities are AEs and which clause triggers.
SHSafe Harbour Eligibility Checker
Given your service type and transaction value, shows whether you qualify under Rule 10TD and Notification 21/2025 (₹300 crore threshold from AY 2025-26).
3CForm 3CEB Clause Wizard
25 clauses of Form 3CEB, one screen at a time. For each clause: what you need to declare, what documents to attach, and what penalty applies under Section 271BA (₹1 lakh for non-filing) or Section 271AA (2% of transaction value for non-maintenance).
31 Oct
Form 3CEB filed every year, no exceptions
15 days
Rule 10D documentation assembled
Zero
Safe Harbour challenges in opted-in years
Figures reflect firm-wide client outcomes. Individual results vary.
Transfer Pricing — In Depth
Form 3CEB Filing Guide AY 2026-27 — Every Clause, Every Document, Every Deadline
Article coming soon — subscribe via WhatsApp for updates.
Associated Enterprise Test — 13 Ways Two Companies Become AEs Under Section 92A
Article coming soon — subscribe via WhatsApp for updates.
Safe Harbour Rules 2025 — New ₹300 Crore Threshold (CBDT Notification 21/2025)
Article coming soon — subscribe via WhatsApp for updates.
Frequently Asked Questions
Does Transfer Pricing apply if my Indian company has only one small transaction with a foreign parent?
Section 92(1) contains no monetary threshold — any international transaction between AEs is subject to arm's length pricing. However, the documentation requirement under Rule 10D applies only if aggregate international transactions exceed ₹1 crore in the previous year.
What are the 13 tests for "Associated Enterprise" under Section 92A?
Equity ≥26%, loans ≥51% of book-value of borrower's assets, guarantees ≥10% of total borrowings, ≥50% appointment of board/governing board, control over appointment of ≥1 director when another enterprise also does so, ≥50% raw-material dependence, ≥90% of goods sold to one enterprise, IP dependence, mutual interest per CBDT discretion — Section 92A(2)(a)–(m) lists all 13.
What is the deadline for Form 3CEB for AY 2026-27?
31 October 2026. The ITR-6 (for TP cases) is due 30 November 2026 (Section 139(1) second proviso). Missing Form 3CEB attracts a ₹1 lakh penalty under Section 271BA.
What is Safe Harbour and has the threshold changed recently?
Safe Harbour under Rule 10TD allows eligible taxpayers to pay a pre-specified operating margin without a benchmarking study. CBDT Notification 21/2025 dated 25 March 2025 raised the threshold from ₹200 crore to ₹300 crore for software development, ITES, KPO, contract R&D (software), and contract R&D (generic pharma). Lithium-ion batteries for EVs/hybrid EVs were added under Rule 10TA(b).
Do I need a Master File if my group revenue is ₹600 crore?
Rule 10DA requires a Master File (Form 3CEAA Part B) if consolidated group revenue exceeds ₹500 crore AND the Indian entity's international transactions exceed ₹50 crore or IP-related transactions exceed ₹10 crore. If your group is ₹600 crore and both secondary thresholds apply, yes.
What is CbCR and when does it apply?
Country-by-Country Reporting under Rule 10DB / Section 286 applies when consolidated group revenue exceeds ₹6,400 crore (Notification 88/2018). Forms 3CEAC (parent intimation), 3CEAD (CbC report), and 3CEAE (designated entity) are required.
What is the Section 94B thin-capitalisation rule?
Section 94B disallows interest paid or payable to a non-resident AE to the extent it exceeds 30% of EBITDA (or the actual net interest expense, whichever is lower) when aggregate interest exceeds ₹1 crore. The disallowed amount can be carried forward for 8 years.
What is a secondary adjustment under Section 92CE?
If a primary TP adjustment exceeds ₹1 crore, Section 92CE requires a secondary adjustment — treating the excess as a deemed loan from the Indian company to its AE and imputing interest. The imputed interest rate is SBI 1-year MCLR + 3.25% for INR transactions (Rule 10CB). The assessee may elect to pay 18% one-time tax (Section 92CE(2A)) instead of imputing interest.
Has India enacted Pillar Two (GloBE rules)?
No. India has not enacted the Global Minimum Tax (QDMTT, IIR, or UTPR) as of AY 2026-27. Finance Act 2025 did not introduce GloBE rules. Indian entities face Pillar Two exposure only at the Ultimate Parent Entity level in jurisdictions that have enacted it. Indian disclosure obligations are limited to AS 22 / Ind AS 12 amendments on deferred tax.
What documents does Rule 10D require?
Rule 10D prescribes 13 categories of TP documentation — description of the group and Indian entity, nature and terms of international transactions, description of functions, assets and risks of each party, records of economic and market analysis, background material, FAR analysis, comparables details, uncontrolled transaction data, AE financials, and projected financial information where relevant. Documentation threshold: aggregate international transactions > ₹1 crore.
Transfer pricing is not a year-end exercise — it is a transaction-design decision. Talk to us before the deal closes.
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