Navigate Transfer Pricing Compliance with Clarity
In a Better Regulated Financial Environment
Cross-border transactions between associated enterprises are subject to detailed review under India’s Transfer Pricing regulations. Proper documentation under Section 92D is not only a statutory requirement but also critical to support the arm’s length nature of intercompany transactions.
At CA Lekshmi N Iyer & Associates, we assist with the preparation of transfer pricing documentation, including:
- Local File
- Master File (Form 3CEAA)
- Benchmarking reports tailored to industry-specific pricing practices and functional profiles
Our approach ensures documentation is aligned with regulatory expectations and ready to support assessments, if required.
We provide advisory and documentation support in line with the Income Tax Act, OECD guidelines, and applicable ICAI standards.
Transfer Pricing Documentation Services We Offer
We provide documentation support in accordance with Indian transfer pricing regulations, including preparation and filing of statutory forms and reports:
- Local File Preparation
Analysis of international transactions, functional (FAR) profiling, and preparation of supporting documentation as per Section 92D. - Benchmarking Analysis
Determination of the Arm’s Length Price (ALP) using suitable methods such as CUP, TNMM, or other prescribed approaches. - Master File (Form 3CEAA) Preparation
Documentation of group structure, intangible asset ownership, and consolidated financial details for multinational enterprises. - Form 3CEB Filing
Chartered Accountant-certified disclosure of international and specified domestic transactions under Rule 10E. - Review & Risk Assessment for TP Cases
Assistance in identifying documentation gaps and preparing responses for scrutiny involving transfer pricing queries or adjustments.
Services include transaction mapping, economic analysis, documentation drafting, and timely compliance filings.
- Local File Preparation
Transfer Pricing Documentation with Regulatory Clarity
Inadequate or missing documentation for cross-border transactions may result in scrutiny or compliance challenges under transfer pricing regulations. Maintaining detailed, regulation-aligned documentation supports transparency, consistency, and preparedness in case of departmental review.
Well-structured transfer pricing files also reflect sound governance practices and are increasingly expected by stakeholders in cross-border operations.
Structured, compliant, and aligned with your group’s operating model
Transaction Mapping & Entity Profiling
Identify and document the nature, scope, and business rationale of intercompany transactions.Functional, Asset & Risk (FAR) Analysis
Analyze the roles, resources, and risk exposure of each participating entity in the transaction chain.Benchmarking Study
Determine the Arm’s Length Price (ALP) using appropriate methods and reliable data sources, in line with regulatory requirements.Documentation Compilation
Prepare statutory transfer pricing files, including the Local File, Master File, and Country-by-Country Report (if applicable), in accordance with Section 92D and Rule 10D.Review & Filing Support
Assist with reviewing documentation, verifying compliance thresholds, and fulfilling applicable reporting and disclosure obligations.
Driving Global Compliance for Indian Entities
Subsidiaries
Ensure transactions with parent companies are priced fairly and defensibly.
Startups with Foreign Capital
Stay compliant from day one when raising or repatriating funds across borders.
Service Providers
TP studies for offshore contracts, inter-company services, and shared costs.
Exporters
Determine ALP for goods or IP licensed between related parties.
Transfer Pricing Documentation FAQs
Common Questions on Transfer Pricing Compliance in India
What is transfer pricing and why does it matter?
Transfer pricing refers to the pricing of transactions between related entities across borders, such as the transfer of goods, services, royalties, or loans. The law requires these transactions to be conducted at Arm’s Length Price—the price that would be charged between unrelated parties under similar conditions.
Who needs to maintain transfer pricing documentation?
Any Indian entity that enters into international transactions or specified domestic transactions with related parties, and crosses prescribed monetary thresholds, must maintain documentation under Section 92D of the Income Tax Act
What happens if I don’t file Form 3CEB or TP documentation?
Failure to file Form 3CEB or maintain transfer pricing documentation may result in penalties under Section 271BA and potential adjustments to taxable income during scrutiny. Timely compliance helps reduce the risk of such outcomes.
What methods are used for benchmarking?
Benchmarking is conducted using prescribed methods under Indian transfer pricing rules, such as:
- CUP (Comparable Uncontrolled Price Method)
- TNMM (Transactional Net Margin Method)
- RPM (Resale Price Method)
CPM, Profit Split, and others depending on transaction type and data availability.
