Transfer pricing applies to related-party transactions
International transactions with associated enterprises generally require arms-length analysis and Form 3CEB certification. Specified domestic transactions may also require documentation where thresholds are crossed.
Situations this page is built for
- Indian subsidiary of an MNC with management fee, royalty or intercompany loans.
- Indian company exporting services to group companies abroad.
- Startup with foreign parent funding via intercompany loan.
- Domestic group with large related-party transactions.
- Company that received a TP adjustment notice.
Documents and details usually required
- List of related-party transactions with amounts.
- Company financials and group structure.
- Intercompany agreements for service, loan, royalty or distribution.
- Comparable uncontrolled pricing data or benchmarking data.
- Previous Form 3CEB and TP study.
- Transfer pricing notice or adjustment order, if any.
Practical process
Map transactions
Identify each associated enterprise and transaction category.
Choose TP method
Select TNMM, CUP, RPM or other method based on facts.
Benchmark
Use comparable data and filters to test arms-length price.
Prepare documentation
Document facts, method, comparables and conclusion.
Certify Form 3CEB
Get certification and file with the tax return.
Common mistakes
- Not maintaining contemporaneous documentation before filing date.
- Using wrong TP method for the transaction type.
- Not updating study when business model changes.
- Ignoring domestic TP thresholds.
How to use this page safely
Transfer Pricing Study & Documentation can depend on financial year, entity type, turnover, location, portal status, notice dates, transaction volume, documentation quality and whether prior filings were done correctly.
Use this page as preparation guidance. Before filing, responding, registering or appealing, share exact forms, notices, portal screenshots, amounts, due dates and prior acknowledgements with a qualified professional.
A strong WorkIndex quote should clearly state scope, assumptions, documents required, expected timeline, exclusions, and whether follow-up, correction filing or notice-response support is included.
How to compare WorkIndex responses
- Ask whether the expert has handled this exact service type, industry and portal workflow before.
- Confirm whether the quote includes filing only, advisory only, or also reconciliation, correction, response drafting and follow-up.
- Prefer experts who ask for records before final pricing instead of quoting blindly.
- For urgent matters, include statutory deadline, notice/order date, current portal status and financial exposure.
- Keep acknowledgement, computation, challan, report, working papers and communication trail after completion.
Keep these ready before requesting quotes
- PAN, Aadhaar, GSTIN, TAN, DIN, CIN, LLPIN, UAN or registration number as applicable.
- Portal login access or screenshots from Income Tax, GST, MCA, EPFO, ESIC, Startup India or other relevant portals.
- Previous filings, acknowledgements, challans, certificates, orders, notices, audit reports and working papers.
- Bank statements, invoices, contracts, payroll records, books export, rent agreements, transaction reports or board/investor documents relevant to the case.
- A short written summary of what happened, what deadline exists, what help you need and whether support can be remote or must be local.
How to get better quotes faster
- Mention whether you need a one-time filing, urgent correction, registration, audit, monthly retainer, appeal, or advisory review.
- Add approximate transaction count, employee count, turnover range, number of filings/years pending, and any notice deadline so experts can size the work properly.
- For accounting and bookkeeping pages, share the software used, number of bank accounts, monthly invoice count, GST status, payroll size and whether old cleanup is needed.
- For audit and diligence pages, share the review period, location count, materiality level, report format expected and who will consume the report: founder, investor, bank, board or tax department.
- For tax and GST disputes, upload or summarise the section/form/order number, demand amount, date of service, due date and current portal status before asking for a fee quote.
FAQs
Is TP study mandatory if transactions are small?
Applicability depends on transaction type and thresholds; get a specialist to review before assuming exemption.
What is the penalty for missing Form 3CEB?
Penalties can apply for non-filing, inaccurate reporting or missing documentation. Exact exposure depends on facts.
How long does a TP study take?
Simple cases may take days, while benchmarking-heavy studies may take weeks.
Does WorkIndex have CAs with Big 4 TP experience?
Post that requirement clearly so specialists with relevant background can respond.