Transfer Pricing Study & Form 3CEB
Comprehensive transfer pricing documentation for Indian entities with cross-border related-party transactions. OECD-aligned benchmarking, Form 3CEB certification, and APA support — all before the 30 November deadline.
92–92F
Section
3CEB
Form
Intl. Txns ≥ ₹1 Crore
Threshold
30 November
Due Date
CUP/RPM/CPM/TNMM/PSM
Methods
2% of Txn Value
Penalty
What is Transfer Pricing?
Transfer pricing refers to the prices at which transactions occur between associated enterprises (AEs) — companies that are related through common ownership or control across international borders. Indian tax law under Sections 92 to 92F of the Income Tax Act, 1961 mandates that all such transactions be conducted at an arm's length price (ALP).
An arm's length price is the price that independent, unrelated parties would agree to for a comparable transaction in similar market conditions. If your company charges below-market prices for services rendered to an overseas parent, or pays above-market royalties to a foreign licensor, the Income Tax Department can make an adjustment — treating the difference as additional taxable income in India.
A Transfer Pricing Study is a detailed economic report that documents your transactions, benchmarks prices against comparable market data, and certifies through Form 3CEB that all international related-party transactions are at arm's length. This study is mandatory when your aggregate international transactions with AEs exceed ₹1 crore in any financial year.
Starting from
₹29,999
Comprehensive TP Study + 3CEB
Who Needs a Transfer Pricing Study?
If any of these describe your business, you are likely required to comply with Indian TP regulations.
Indian Subsidiaries of MNCs
Indian arms of foreign multinationals must benchmark all cross-border related-party transactions annually.
Overseas Related-Party Transactions
Any Indian company with imports, exports, or service transactions with foreign group entities.
Management Fee Recipients
Companies receiving management services, IT support, or shared services from their parent entity abroad.
Inter-Company Lenders
Indian companies extending loans to or receiving loans from foreign associate enterprises.
Cross-Border Joint Ventures
JVs involving non-resident partners where income or cost allocation crosses the international border.
ESOP Beneficiaries
Indian employees receiving stock options from a foreign parent — the recharge creates an international transaction.
Royalty-Paying Entities
Indian HQs or subsidiaries paying royalties, technical fees, or brand licence fees to overseas entities.
Cross-Border Service Arrangements
Back-office BPO/KPO services, software development, or any inter-company service arrangement with non-residents.
Why Commission a TP Study?
Beyond statutory compliance, a well-crafted transfer pricing study provides significant business and legal value.
Avoid 2% Penalty
A documented TP study is your primary defence against the 2% penalty on the transaction value for non-compliance.
OECD Guideline Compliance
Study aligned with OECD transfer pricing guidelines and BEPS Action Plans for global consistency.
Minimise TP Risk in Audit
Robust documentation reduces the risk of TP additions and adjustments during Income Tax scrutiny.
APA Support
We assist with Unilateral, Bilateral, and Multilateral Advance Pricing Agreements for 5-year price certainty.
Arm's Length Defence
Comprehensive economic analysis and comparables selection provide a legally defensible arm's length position.
Reduce Double Taxation
Proper documentation enables effective use of DTAA MAP (Mutual Agreement Procedure) to eliminate double tax.
Functional Analysis Clarity
FAR (Functions, Assets, Risks) analysis provides a clear economic picture of each entity's role in the group.
CbCR Compliance
We prepare Country-by-Country Report (3CEAA/3CEAB) for Indian constituent entities of large MNC groups.
8-Step Transfer Pricing Process
A structured, methodical approach ensures your TP documentation is rigorous and audit-ready.
Identify International Transactions
Map all transactions with associated enterprises (AEs) — goods, services, loans, intangibles, and guarantees.
Functional Analysis (FAR)
Document functions performed, assets employed, and risks assumed by each entity in the value chain.
Comparability Analysis
Identify economically comparable transactions or companies using databases (Prowess, Capitaline, TP Catalyst).
Select Transfer Pricing Method
Choose the most appropriate method: CUP, RPM, CPM, TNMM, or Profit Split based on transaction characteristics.
Benchmarking Study
Run statistical analysis on comparable set; compute arm's length price or margin range using the selected method.
Prepare 3CEB Report
Draft the accountant's report in Form 3CEB covering all international transactions with mandated disclosures.
CA Certification
A Chartered Accountant certifies the Form 3CEB after due diligence review of all underlying documents.
File with ITR + Maintain Records
Submit 3CEB with the Income Tax Return and maintain complete documentation for 8 years as required by law.
Documents Required
Transfer pricing documentation in India is governed by Rule 10D. The following documents form the core of a compliant TP file. We guide you through collection and organisation.
Rule 10D Documentation
Mandatory record maintenance
Under Rule 10D of the Income Tax Rules, every person required to maintain information and documentation must keep these records for a period of 8 years from the end of the relevant assessment year.
Failure to maintain prescribed documentation not only attracts a 2% penalty on the transaction value but also shifts the burden of proof entirely to the taxpayer during assessment.
TP documentation must be in place before the due date of filing the Income Tax Return. It need not be filed but must be produced within 30 days of a notice from the Assessing Officer.
6-Stage Engagement Timeline
From kickoff to 3CEB certification — a typical engagement takes 3–6 weeks depending on complexity.
Transaction Identification
List all AE transactions and classify by nature.
FAR Analysis
Functional interview and economic profiling of each entity.
Method Selection
Apply method selection hierarchy per Rule 10C.
Benchmarking
Database search, comparables filtering, arm's length range.
Report Drafting
Prepare TP Study Report and Form 3CEB draft.
3CEB Certification
CA review, certification, and filing with ITR.
What You Receive
Every TP engagement from Company Avenue Advisory delivers a complete, audit-ready documentation package.
Transfer Pricing Study Report (detailed)
Form 3CEB — CA certified and signed
Benchmarking analysis with database excerpts
Functional interview notes (FAR documentation)
Economic analysis document
Comparability analysis workings
Why Company Avenue Advisory?
Team of experienced CAs with international tax expertise
Access to premium TP databases — Prowess, Capitaline, TP Catalyst
OECD and BEPS-aligned documentation approach
Legally defensible arm's length analysis
APA filing and MAP representation support
Country-by-Country Reporting (CbCR) assistance
Dedicated TP expert assigned to your engagement
Delivery before 30 November deadline — guaranteed
Frequently Asked Questions
Everything you need to know about transfer pricing compliance in India.
You May Also Need
30 November Deadline Is Approaching
Don't wait until October. Commission your Transfer Pricing Study now and ensure your Form 3CEB is certified and ready well before the deadline.