TP Documentation
Preparing the local file, master file and supporting records required to substantiate your transfer pricing position.
Transfer pricing documentation in India comprises the local file (entity-specific transaction and benchmarking details), and, above prescribed thresholds, a master file giving a group-wide overview of the multinational enterprise's business and TP policies. This documentation must be maintained contemporaneously and furnished on request, and it directly supports the Form 3CEB accountant's certification filed with the return.
What documentation compliance involves
Documentation needs to be both complete and internally consistent with the study and the benchmarking analysis behind it.
- Preparing entity-level local file documentation
- Assessing master file applicability based on group and entity thresholds
- Maintaining prescribed records under Rule 10D
- Ensuring consistency between documentation, study and Form 3CEB
- Setting up systems for contemporaneous record-keeping through the year
- Preparing documentation for timely retrieval if called for by authorities
What this service includes
How we help you stay documentation-ready.
Local File Preparation
Compiling entity-specific transaction details, agreements and benchmarking support.
Master File Assessment
Determining applicability and preparing group-level documentation where required.
Rule 10D Record-Keeping
Setting up the prescribed records required to be maintained under the TP rules.
Consistency Checks
Reconciling documentation against the TP study and Form 3CEB before filing.
Our process
From initial consultation to completion.
Requirement Assessment
Determining which documentation obligations apply based on your thresholds.
Local File Compilation
Preparing entity-specific documentation with full transaction detail.
Master File Preparation
Building group-level documentation where the threshold is crossed.
Review & Filing Readiness
Finalising documentation ready for filing or retrieval on request.
Why documentation quality is a compliance issue on its own
What sets our approach apart.
Penalties apply independent of any pricing dispute
Failure to maintain or furnish documentation attracts its own penalty, regardless of whether the pricing itself is later upheld.
Contemporaneous records carry more weight
Documentation prepared during the year is viewed more credibly than records assembled after a notice arrives.
Master file thresholds are easy to miss
Group-level revenue and transaction thresholds can trigger master file obligations even for a modestly sized Indian entity.
TP documentation questions answered
What people ask before engaging us.
Keep your TP documentation contemporaneous and complete.
Let our team help you navigate this process with clarity and confidence.
