Transfer Pricing Documentation Requirements
Transfer pricing documentation is required for companies with international transactions above specified thresholds. The following is a general overview.
Applicability
- International transactions with associated enterprises exceeding INR 1 crore in aggregate
- Specified domestic transactions with associated persons exceeding INR 20 crores
Key Documentation
- Transfer pricing study / benchmarking analysis
- Form 3CEB — Accountant's Report (mandatory for qualifying transactions)
- Master File (Form 3CEAA) — for qualifying groups
- Country-by-Country Report (Form 3CEAD) — for qualifying groups
Penalties for Non-Compliance
- Late/Non-filing of Form 3CEB: INR 100,000
- Inadequate documentation: 2% of transaction value
- Transfer pricing adjustment: 100-300% of tax on adjustment
Advisory note: Transfer pricing thresholds, documentation requirements and penalty provisions are subject to change. This overview is for general information only. Tax and regulatory conclusions require qualified professional review.
Advisory note: This guide is for general information and awareness purposes only. Inaac Advisors provides advisory and execution support — not legal, tax, or regulatory opinions. Legal, tax, immigration and regulatory conclusions require qualified professional review.
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