Domestic and international transfer pricing studies, planning, and Form 3CEB certification.
Transfer pricing in India has evolved into a highly sophisticated and aggressively scrutinized regulatory framework. Governed by the newly restructured provisions of the Income-tax Act, 2025, and the updated Income-tax Rules, 2026, justifying the pricing of intra-group transactions is no longer merely an annual compliance exercise—it is a core component of corporate tax risk management.
We assist multinational enterprises and domestic conglomerates in aligning their global value chains with Indian regulations, ensuring that all international and Specified Domestic Transactions (SDTs) are accurately benchmarked at the Arm's Length Price (ALP).
With the implementation of the new legislative framework effective April 1, 2026, the compliance landscape has witnessed a paradigm shift. We guide clients through these critical updates, including the transition to the new Form 48 (which replaces the traditional Form 3CEB) for the accountant's report, bringing expanded and highly structured disclosure requirements.
ApplicabilityTransfer pricing provisions apply to all international transactions with Associated Enterprises (AEs) regardless of transaction value, and to Specified Domestic Transactions (SDTs) that exceed threshhold limits.
Mandatory DocumentationWhile the Arm's Length Principle must be applied to every transaction, detailed statutory documentation (the Local File) is legally required only if the aggregate value of your international transactions exceeds limits.
Stringent PenaltiesFailure to maintain proper transfer pricing documentation, furnish the accountant's report, or report a transaction attracts severe penalties, which now feature a graded fee structure based on the period of delay.
An AE is an enterprise that participates directly or indirectly in the management, control, or capital of another enterprise. This includes strict numerical thresholds, such as holding voting power, significant loan dependencies, or control over the board of directors.
It can, for specified domestic transactions above prescribed thresholds. We will assess your applicability.
An analysis comparing your related-party pricing against independent comparables to demonstrate it is at arm's length.
Yes. Even if your transactions fall below the ₹1 crore threshold—which exempts you from maintaining the detailed Local File documentation—you are still legally required to compute the income at the arm's length price and file the Accountant's Report.
Safe Harbour Rules define specific circumstances and margins under which tax authorities will accept the transfer price declared by the taxpayer without a detailed audit. The 2026 amendments made this highly beneficial for IT/ITeS and data center companies by prescribing unified margins and raising the eligibility threshold
An APA is a preemptive, binding agreement between a taxpayer and the tax authorities. It determines the transfer pricing methodology and the arm's length price for international transactions for up to five future years, with an option to roll back the agreement to four prior years, effectively removing audit risk for the covered period.
The law prescribes six methods: CUP, RPM, CPM, PSM, TNMM, and the 'Other Method.' The 'Most Appropriate Method' depends entirely on the nature of the transaction, the availability of reliable comparable data, and the functions performed. TNMM (Transactional Net Margin Method) remains the most widely utilized method in India.
Yes. We represent and support you if your transfer-pricing positions are examined.
Tell us a little about your requirement and our team will get back to you with the right guidance and a clear next step.
