If your Indian entity transacts with group companies abroad, Indian law requires the pricing to be at arm's length, documented in a transfer-pricing study, and certified annually in Form 48 (formerly Form 3CEB).
Who needs this
- Every Indian entity with international transactions with associated enterprises — including a subsidiary charging cost-plus to its parent, or paying royalties, management fees or interest.
- Certain large domestic groups (specified domestic transactions).
What we do
- Benchmark the transactions using Indian databases; prepare the local file/transfer-pricing study.
- Issue the accountant's report (Form 48) and advise on Master File (Form 56) and CbCR (Forms 58/59) thresholds for larger groups.
- Support advance pricing agreements and defend positions in audit.
What you receive
- Transfer-pricing study; filed Form 48; inter-company agreement review notes.
Key deadlines
| Item | Rule |
|---|---|
| Form 48 | 31 October |
| Income-tax return for entities with international transactions | 30 November. (Due dates and Master File/CbCR thresholds under the 2026 Rules to be re-confirmed each year.) |
Documents you'll need
- Inter-company agreements; segmental P&L; group transfer-pricing policy; details of all cross-border related-party transactions
Download the document checklist (PDF)
Questions we are asked most
Who needs Transfer pricing?
Every Indian entity with international transactions with associated enterprises — including a subsidiary charging cost-plus to its parent, or paying royalties, management fees or interest. Certain large domestic groups (specified domestic transactions).
What documents do you need for Transfer pricing?
Inter-company agreements; segmental P&L; group transfer-pricing policy; details of all cross-border related-party transactions.
What do you deliver for Transfer pricing?
Transfer-pricing study; filed Form 48; inter-company agreement review notes.
Last updated: September 21, 2026.