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—International Taxation & Transfer Pricing

Transfer Pricing Study & Documentation

Functional analysis, benchmarking and documentation for international and specified domestic transactions.

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Handled by a practising Chartered Accountant or Company Secretary.

Scope of work

Functional analysis, benchmarking and documentation for international and specified domestic transactions.

Key deliverables

  • Transfer pricing study / local file

Governing law

Income-tax Act (1961 / 2025, as applicable to the period) (transfer pricing provisions)

Frequency

Annual

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Transfer Pricing Study & Documentation

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  • Transfer pricing study / local file
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Transfer Pricing Study & Documentation + Compliance Care

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+ ₹9,599/yr for year-one ROC compliance

  • Transfer pricing study / local file
  • Financial statements in Schedule III format
  • Board report and AGM notice
  • Filed AOC-4 with SRN
  • Filed MGT-7 / MGT-7A with SRN
  • Board and AGM minutes
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—A closer look

Understanding transfer pricing documentation

Everything below is written for companies with cross-border group transactions — what transfer pricing is, what India requires you to document, and how a TP study is built.

What is a transfer pricing study?

Transfer pricing is the pricing of transactions between related parties — for example, an Indian subsidiary providing software services to its foreign parent, buying products from a group company, or paying royalties or management fees. India requires these 'international transactions' with associated enterprises to be at arm's length: the price unrelated parties would agree.

A transfer pricing study analyses the transactions, the functions performed, assets used, and risks assumed by each party, selects a method, benchmarks against comparable independent companies, and documents why the price is arm's length. Businesses above the threshold must keep this documentation every year.

The key terms

The building blocks of transfer pricing:

Associated enterprise
A related party, typically through shareholding, control, or management, as defined in the Act.
International transaction
A transaction between associated enterprises where at least one is a non-resident — services, goods, royalties, loans, guarantees, and cost allocations.
Specified domestic transaction
Certain transactions between related domestic parties above a threshold, also subject to transfer pricing.
FAR analysis
An analysis of the Functions performed, Assets used, and Risks assumed by each party, which drives the method and benchmarking.
Methods
Comparable uncontrolled price, resale price, cost plus, profit split, transactional net margin (TNMM), and other methods. TNMM is the most commonly used.
Arm's length range
Where there are enough comparables, the price is tested against a range based on percentiles of comparable results.
Documentation threshold
Detailed documentation must be maintained where the aggregate value of international transactions exceeds ₹1 crore.

A simple example

A Hyderabad subsidiary of a US software company provides development services to its parent at cost plus 15%. The TP study documents that the subsidiary performs routine development under the parent's direction, with limited risk. Using TNMM, it benchmarks the subsidiary's operating margin against independent Indian software service companies with similar functions. The comparable companies' margins form a range, and the subsidiary's 15% mark-up falls within it — supporting the price. The study is updated each year with current comparables.

Why it matters

Transfer pricing is one of the most litigated areas of Indian tax:

Adjustments
If the price isn't at arm's length, the tax officer can adjust income upwards, with tax and interest.
Penalties
Failure to keep documentation, or to report transactions, attracts significant penalties.
Scrutiny focus
Transfer pricing cases are selected for detailed examination by specialist officers.
Accountant's report
Transactions must be reported annually in a CA's report, which depends on the study.
Double taxation
An Indian adjustment can mean the same profit is taxed in two countries unless relief is obtained.
Business credibility
Groups need defensible pricing in every country they operate in.
Planning
Setting prices right at the start is far cheaper than defending them later.

Who is this for?

  • Indian subsidiaries of foreign groups, including global capability centres
  • Indian companies with foreign subsidiaries
  • Companies paying royalties, management fees, or cost allocations to group companies
  • Companies with intra-group loans or guarantees
  • Groups with specified domestic transactions above the threshold

Safe harbour rules offer certainty for some transactions if prescribed margins are accepted — worth considering for routine services.

Common transfer pricing methods

Choosing the most appropriate method:

AspectTNMMCost plusCUPProfit split
ComparesNet margins with comparable companiesGross mark-up on costsPrices in comparable transactionsDivision of combined profit
Common useRoutine services, distribution, manufacturingManufacturing and services with good cost dataCommodities, loans, some royaltiesHighly integrated operations
Data needsCompany-level financial dataGross margin dataTransaction-level price dataDetailed contribution analysis
PracticalityHigh — most usedModerateDepends on data availabilityComplex

What we'll need from you

Group structure
The group chart and relationships with associated enterprises.
Intercompany agreements
Agreements for each type of transaction.
Transaction data
Values of each international transaction for the year.
Financial statements
The Indian entity's accounts, and segmental data where relevant.
Functional information
Interviews with management about functions, assets, and risks.
Group policies
The group's transfer pricing policy and any master file.

Fees depend on the number and types of transactions and whether it's a first-year study or an update.

How a TP study is built

Each year's documentation follows these steps:

  1. 1

    Identify transactions

    All international and specified domestic transactions are identified and valued.

  2. 2

    FAR analysis

    Functions, assets, and risks are analysed through interviews and documents.

  3. 3

    Select the method

    The most appropriate method is chosen and justified.

  4. 4

    Benchmark

    Comparable independent companies or transactions are searched and screened.

  5. 5

    Test and conclude

    The price is tested against the arm's length range.

  6. 6

    Document and report

    The study is prepared, and the CA's report on transactions filed.

Keeping transfer pricing on track

TP is annual work:

Year-end true-ups
Adjust prices before year end if results fall outside the range.
Update comparables
Refresh benchmarking every year.
Keep agreements current
Update intercompany agreements when arrangements change.
File the accountant's report
File the CA's report on transactions by the due date.
Consider an APA
For certainty over future years, consider an Advance Pricing Agreement.
Keep documentation
Keep the study and support for the retention period.

Benefits and responsibilities

Benefits

  • Documentation that meets Indian requirements
  • Prices tested against current comparables
  • Lower risk of adjustments and penalties
  • A defensible position in assessments
  • Consistency with group policy

Responsibilities

  • Share all intercompany transactions
  • Keep intercompany agreements in place
  • Provide access for functional interviews
  • Make year-end adjustments where needed
  • File the accountant's report on time
  • Keep documentation for the retention period

—FAQ

Questions finance teams actually ask us

If you have international transactions with associated enterprises, they must be at arm's length and reported. Detailed documentation must be kept where their aggregate value exceeds ₹1 crore.