What this covers
Establishing and documenting that transactions between associated enterprises are priced at arm's length. It covers the functional analysis, selecting the most appropriate method, benchmarking against comparable data, the documentation the Rules require, and the accountant's report on international transactions.
Statutory basis
The transfer pricing provisions of the Income-tax Act, 2025, read with the Income-tax Rules, 2026. The Act came into force on 1 April 2026 and repealed the Income-tax Act, 1961, under which the corresponding provisions were sections 92 to 92F with Rules 10A to 10THD of the 1962 Rules — the accountant's report was required by section 92E in Form 3CEB, the documentation by Rule 10D, the choice of method by Rule 10C, and Master File and Country-by-Country reporting by section 286 with Rules 10DA and 10DB. Those form numbers and rule references changed with the new Rules, so we confirm the current form before filing.
Who it applies to
Any person entering into an international transaction with an associated enterprise, and specified domestic transactions above the threshold the Act prescribes — formerly section 92BA. The accountant's report is required irrespective of the value of the international transaction: there is no de minimis for the report itself, only for the detailed documentation.
What we do
- 1Map the group structure and identify every associated enterprise and international transaction, including ones easily missed such as guarantees, interest-free balances and cost allocations.
- 2Carry out the functional, asset and risk analysis for each tested party.
- 3Select the most appropriate method under the rule that governs the choice, and document why the alternatives were rejected.
- 4Run the benchmarking search, apply and record the filters, and compute the arm's length range.
- 5Prepare the documentation the Rules require, and the Master File or Country-by-Country forms where the thresholds are met.
- 6Issue the accountant's report on the current form, and support the position if it is taken up in a transfer pricing assessment.
What you receive
- Accountant's report
- The report on international transactions, filed and acknowledged on the form current for the year.
- Study
- The transfer pricing study with the functional analysis, method selection and benchmarking working.
- Search record
- The comparables set with the accept–reject matrix, so the analysis can be defended years later.
Documents and information required
Group structure and shareholding chart · agreements for each international transaction · segmental financials for the tested party · description of functions, assets and risks · details of the associated enterprises and their jurisdictions · prior-year study and accountant's report · any assessment or appellate order on transfer pricing · budgets and cost allocation keys.
Key dates
The accountant's report is ordinarily due one month before the due date for the return of income of a taxpayer with an international transaction, and the documentation must be in place by then. The Master File and the intimation identifying the entity that will file it run on their own dates. For tax year 2026-27, the first year under the new Act and Rules, we confirm the operative date and form.