International TP
Pricing and documenting cross-border transactions between associated enterprises at arm's length.
International transfer pricing applies to transactions such as sale of goods, provision of services, royalty, cost allocation and financing arrangements between an Indian entity and its overseas associated enterprises. These transactions must be priced at arm's length under Sections 92 to 92F, supported by a benchmarking study and documented through a Form 3CEB accountant's report. Cross-border transactions typically draw greater scrutiny, making robust, contemporaneous documentation especially important.
What international TP compliance involves
Cross-border pricing questions usually combine an Indian-law analysis with an awareness of the counterparty jurisdiction's expectations.
- Identifying all cross-border transactions with overseas AEs
- Selecting the most appropriate transfer pricing method
- Benchmarking using comparable uncontrolled transactions or entities
- Preparing master file and local file where thresholds are met
- Assessing exposure to secondary adjustments and thin capitalisation rules
- Coordinating with group transfer pricing policy where one exists
What this service includes
How we support your cross-border transactions.
Cross-Border Transaction Mapping
Identifying all transactions with overseas group entities that fall under the regime.
Method & Benchmarking
Selecting the pricing method and running the benchmarking analysis for your fact pattern.
Master File & Local File
Preparing group-level and entity-level documentation where thresholds require it.
Group Policy Alignment
Aligning Indian TP positions with the broader group's global pricing policy.
Our process
From initial consultation to completion.
Transaction & AE Identification
Mapping every cross-border transaction with associated enterprises.
Method Selection
Determining the most appropriate arm's length method for each transaction type.
Benchmarking & Documentation
Building the comparable analysis and preparing the required documentation.
Certification & Filing
Issuing Form 3CEB and filing it in time with the return.
Why international transactions need extra rigour
What sets our approach apart.
Higher scrutiny than domestic transactions
Cross-border pricing is a recurring audit focus area, so documentation quality matters more here.
Currency, geography and comparability add complexity
Selecting genuinely comparable data across jurisdictions takes more careful judgment than domestic benchmarking.
Master file obligations apply at group level
Beyond your entity's own file, group-wide thresholds may trigger additional master file requirements.
International TP questions answered
What people ask before engaging us.
Get your cross-border transactions audit-ready.
Let our team help you navigate this process with clarity and confidence.
