Tax Advisory
    Service

    Transfer Pricing Documentation.

    If you transact with associated enterprises abroad, or have specified domestic transactions, the law requires you to show those prices are at arm's length and to keep supporting documentation. We scale the work to your transactions, from a full study with functional and benchmarking analysis to a lighter file for smaller volumes, ready for the accountant's report and any later scrutiny.

    See how it works

    Free 30-minute call with a partner

    About Transfer Pricing Documentation. No obligation — we reply within one business day.

    Typical timeline

    Typically three to six weeks, and longer in the first year or with many transaction types. Time depends on how quickly functional interviews happen, agreements are located and segmental data is prepared.

    Who leads it

    A partner — a chartered accountant or company secretary — from the first call to sign-off.

    Fees

    Based on your situation, and fixed in writing before any work starts.

    Who it's for

    Is this for you?

    • Indian subsidiaries and branches of foreign groups
    • Indian companies with overseas subsidiaries, joint ventures or related-party loans
    • Businesses with specified domestic transactions with related parties above the prescribed limit
    • Groups that must also file master file or country-by-country information
    What you get

    What you receive at the end.

    • 01Transfer pricing study, full or abridged depending on scope
    • 02Functional analysis and benchmarking report
    • 03Arm's length computation and any adjustment needed
    • 04Data and schedules for the accountant's report
    • 05Recommendations on intercompany pricing going forward
    How it works

    Transfer Pricing Documentation, step by step.

    Typical timeline

    Typically three to six weeks, and longer in the first year or with many transaction types. Time depends on how quickly functional interviews happen, agreements are located and segmental data is prepared.

    1. 1

      Transaction mapping

      We identify every international and specified domestic transaction with associated enterprises and tie it to the books.

    2. 2

      Functional analysis

      We interview your team to document the functions performed, assets used and risks assumed by each party.

    3. 3

      Method and benchmarking

      We select the most appropriate method and run database searches for comparable companies or transactions.

    4. 4

      Documentation file

      We prepare the study and records that section 171 of the Income-tax Act, 2025 (section 92D of the 1961 Act) requires you to keep.

    5. 5

      Accountant's report support

      We align the documentation with the accountant's report in Form 48 under section 172, or Form 3CEB under section 92E of the 1961 Act for earlier years.

    Before we start

    What we need from you.

    Don't have everything yet? We send a short checklist after the first call and work with what you have.

    • Group structure and shareholding chart
    • Intercompany agreements for goods, services, royalties, loans and guarantees
    • Audited financial statements and segmental data
    • Transaction-wise ledgers with associated enterprises
    • Invoices and pricing policies for related-party transactions
    • Earlier transfer pricing documentation and assessment orders, if any
    How fees work

    The fee depends on your situation. After a short call, the partner who will do the work tells you what's involved and gives you a fixed fee in writing — before any work begins.

    • Government fees and statutory charges are billed at actuals.
    • When you pay — upfront, in stages or on completion — is agreed in writing with the fee.
    FAQs

    Questions about Transfer Pricing Documentation.

    From tax year 2026-27 it is Form 48 under section 172 of the Income-tax Act, 2025. For financial year 2025-26 and earlier years, Form 3CEB under section 92E of the 1961 Act continues to apply.

    Speak with a partner

    Ready to discuss Transfer Pricing Documentation?

    30-minute confidential call — no proposal, no commitment. A partner will write back within one business day.

    Contact details