Transfer Pricing Overview
Transfer Pricing refers to the pricing of transactions between associated enterprises (AEs) or related parties. In India, transfer pricing regulations are governed by Sections 92 to 92F of the Income Tax Act, 1961, and ensure that transactions between related parties are conducted at arm's length.
Key Principles
- Arm's Length Principle (ALP) compliance
- Mandatory documentation requirements
- Annual compliance and reporting
- Audit support and dispute resolution
Applicability
Transfer Pricing provisions apply when:
- An enterprise enters into an international transaction with its associated enterprise
- The aggregate value of international transactions exceeds ₹1 crore in a financial year
- Domestic transactions exceeding ₹20 crore (for specified domestic transactions)
Our Transfer Pricing Services
TP Documentation
Comprehensive transfer pricing documentation and reports
Compliance
Annual compliance and Form 3CEB filing
Audit Support
Support during TP audits and assessments
Benchmarking
Comparability analysis and benchmarking studies
Transfer Pricing Compliance
Comprehensive compliance services to ensure adherence to transfer pricing regulations and avoid penalties.
Compliance Requirements
- Maintenance of transfer pricing documentation
- Filing of Form 3CEB (Certificate from Accountant)
- Arm's Length Price (ALP) determination
- Annual compliance reporting
- Response to notices and queries from tax authorities
Penalties for Non-Compliance
- Penalty @2% of the value of international transaction for non-maintenance of documentation
- Penalty @2% for non-filing of Form 3CEB
- Adjustments and addition to income if ALP is not maintained
- Interest and penalties on adjustments
Transfer Pricing Documentation
Comprehensive documentation services to ensure compliance with transfer pricing regulations.
Documentation Requirements
- Master File and Local File preparation
- Country-by-Country (CbC) reporting (if applicable)
- Comparability analysis and benchmarking
- Functional and risk analysis
- Economic analysis and profit level indicators
Transfer Pricing Audit Support
Expert support during transfer pricing audits and assessments to protect your interests.
Our Audit Support Services
- Preparation for TP audits
- Response to audit queries and notices
- Representation before tax authorities
- Dispute resolution and settlement
- Appellate representation if required