Indian Company Master Data Made Simple

Transfer Pricing Audit and Documentation - Complete Guide

Transfer pricing regulations ensure arm length pricing for international and specified domestic transactions between related parties. Mandatory documentation and accountant reports required for transactions above thresholds.

14 min read 2900 words Updated 13 Feb 2026

Key Points

Transfer pricing applies to international transactions and specified domestic transactions
Transactions must be at arms length price (ALP)
Documentation required if transaction value exceeds ₹1 crore (enterprise level ₹20 crores)
Form 3CEB due by November 30 for reporting related party transactions
Five methods prescribed for determining ALP
TP adjustments can result in additional tax at 30% plus interest and penalties

What is Transfer Pricing?

Transfer Pricing refers to the pricing of goods, services, and intangibles transferred between related entities (associated enterprises) within a multinational enterprise group. Tax authorities scrutinize these transactions to ensure they are conducted at arm's length, meaning the prices are similar to what would be charged between unrelated parties.

Objectives of Transfer Pricing Regulations

  • Prevent Profit Shifting: Stop MNEs from shifting profits to low-tax jurisdictions
  • Ensure Fair Taxation: Each jurisdiction gets fair share of tax revenue
  • Arm's Length Principle: Transactions should reflect market conditions
  • Combat Base Erosion: Prevent artificial reduction of taxable base
  • Transparency: Increase visibility of cross-border transactions

Arm's Length Principle

The cornerstone of transfer pricing is the Arm's Length Principle, which states that the price charged in a controlled transaction (between related parties) should be the same as the price charged in a comparable uncontrolled transaction (between unrelated parties).

Applicability and Thresholds

Type of Transaction Threshold (per FY)
International Transaction > ₹1 crore (aggregate)
Specified Domestic Transaction > ₹20 crores (aggregate)
Master File Consolidated revenue > ₹500 crores
CbCR Consolidated revenue > ₹6,500 crores

Transfer Pricing Documentation

The Income Tax Act mandates three levels of TP documentation: Local File, Master File, and Country-by-Country Report (CbCR).

Local File

  • • Entity-specific information
  • • Description of local operations
  • • Controlled transactions details
  • • Functional analysis (FAR)
  • • Benchmarking study
  • • TP method selection

Master File

  • • Group organizational structure
  • • Group business description
  • • Intangible assets overview
  • • Financial activities
  • • Group TP policies
  • • Financial and tax positions

CbCR

  • • Global revenue by jurisdiction
  • • Profit before tax by country
  • • Income tax paid
  • • Number of employees
  • • Capital and assets
  • • Business activities

Benchmarking Methods

The OECD and Indian TP regulations prescribe several methods to determine arm's length price.

Method Best Suited For
CUP (Comparable Uncontrolled Price) Product transactions with identical/similar goods
RPM (Resale Price Method) Distributors/resellers who add limited value
CP (Cost Plus Method) Manufacturing, assembly, service providers
TNMM (Transactional Net Margin) Most commonly used; services, complex transactions
PSM (Profit Split Method) Highly integrated operations, joint IP development

Form 3CEB and Accountant Report

Every person who enters into international transactions or specified domestic transactions must obtain a report from a Chartered Accountant in Form 3CEB.

Form 3CEB Key Information

  • • Description of each international transaction
  • • Names of associated enterprises
  • • Nature and value of transactions
  • • Transfer pricing method applied
  • • Arm's length price determination
  • • CA's opinion on arm's length compliance

Due Date: November 30 (extended from October 31) of the assessment year.

Transfer Pricing Audit Process

1

Case Selection

Cases selected based on risk parameters, high-value transactions, or random selection.

2

Notice u/s 92CA

Transfer Pricing Officer (TPO) issues notice requiring submission of information.

3

Submission of Documents

Taxpayer submits TP documentation, financials, and responses to queries.

4

TP Adjustment Order

TPO determines arm's length price and proposes adjustment if required.

5

DRP/Appeal

Taxpayer can approach Dispute Resolution Panel or file appeal before ITAT.

Transfer Pricing Adjustments

If the TPO determines that the transaction price is not at arm's length, an adjustment is made, leading to additional tax liability.

Consequences of TP Adjustment

  • • Additional taxable income
  • • Tax at 30% (plus surcharge and cess) on adjusted amount
  • • Interest u/s 234B and 234C
  • • Penalty u/s 271G (for failure to furnish documentation)
  • • Secondary adjustment provisions may apply

Frequently Asked Questions

What is Safe Harbour in Transfer Pricing?

Safe Harbour provisions provide predetermined margins/conditions under which transactions are accepted as arm's length. If taxpayers meet these conditions, they are not subject to TP audit for those transactions.

What is an Advance Pricing Agreement (APA)?

APA is an agreement between taxpayer and tax authority determining TP methodology for future transactions. Provides certainty and avoids disputes. Can be unilateral, bilateral, or multilateral.

Are intra-group loans covered under TP?

Yes, international transactions involving loans, guarantees, or advances between associated enterprises are covered under TP regulations and require benchmarking for interest rates.

Registration Process

1

Identification

Identify all related parties and transactions

2

Threshold Check

Determine if TP provisions apply based on transaction values

3

Documentation

Prepare Master File, Local File, and CbCR if applicable

4

Benchmarking

Perform economic analysis to determine ALP

5

Form 3CEB

Obtain report from Chartered Accountant

6

Filing

File Form 3CEB with Income Tax Return

7

Assessment

Respond to TP audit queries if selected

8

Appeal

File appeal if adverse adjustment order

Documents Required

  • Details of all international transactions with related parties
  • Details of specified domestic transactions (SDT)
  • Functional analysis of taxpayer and comparables
  • Bilateral/unilateral agreements (if any)
  • Transfer pricing documentation (Local File)
  • Master File (if consolidated revenue > ₹500 crores)
  • CbCR (if consolidated revenue > ₹6,500 crores)
  • Financial statements of comparable companies
  • BASIS database search reports
  • Segmental financial statements
  • Inter-company agreements

Cost Breakdown

TP Documentation (Local File)
Master File Preparation
Form 3CEB (CA fees)
Benchmarking Study
CbCR Preparation (if applicable)
APA Application
TP Audit Defense

Frequently Asked Questions

What is Transfer Pricing and when does it apply?

What are the documentation requirements for Transfer Pricing?

What are the five methods for determining Arms Length Price?

What is Form 3CEB and when should it be filed?

What happens during a Transfer Pricing audit?

What are the consequences of Transfer Pricing adjustments?

What is Safe Harbour and when can it be used?

What is Advance Pricing Agreement (APA) and how does it work?

What are Specified Domestic Transactions (SDT) in Transfer Pricing?

How to prepare for a Transfer Pricing audit?

Related Topics

transfer pricingtp documentationtransfer pricing auditinternational taxationrelated party transactions

Ready to Get Started?

Let our experts handle your foreign investment while you focus on your business.