Transfer Pricing
Tax rules requiring international transactions and specified domestic transactions between associated enterprises to be at arm's length price.
Filing window
Form 3CEB filed by 31 October with the income tax return
Regulator
Central Board of Direct Taxes (CBDT)
Regulator
Central Board of Direct Taxes (CBDT)
Deadline
Form 3CEB filed by 31 October with the income tax return
Penalty
Section 271AA: 2 percent of value of international transacti...
Legal basis
Income Tax Act, 1961
What is Transfer Pricing?
Tax rules requiring international transactions and specified domestic transactions between associated enterprises to be at arm's length price.
- +All Indian employers and payers subject to TDS
- +Foreign-owned Indian subsidiaries
- +EOR providers processing client-funded payroll
Statutory basis
Income Tax Act, 1961
Sections 92 to 92F
Rule reference
Rules 10A to 10TG of Income Tax Rules, 1962
Enforced by
Central Board of Direct Taxes (CBDT)
Citations are editorially curated. Always verify current applicability with qualified Indian counsel before acting on a specific matter.
The stake
Filing window for Transfer Pricing. Skipping or mishandling this compliance carries direct financial and operational consequences.
Why Transfer Pricing matters for your GCC
Transfer Pricing is a income tax and withholding requirement for foreign-owned Indian entities and GCCs. Missing the form 3ceb filed by 31 october with the income tax return obligation triggers section 271aa: 2 percent of value of international transaction for documentation failure; section 271ba: penalty of inr 1 lakh for failure to file form 3ceb, and downstream filings or transactions may be blocked until rectification. Most foreign parents discover Transfer Pricing issues only when a downstream transaction surfaces the prior gap, by which point rectification costs and operational delays have grown materially. Proactive handling avoids these cascading consequences.
The 4 ways Transfer Pricing goes wrong
Real scenarios from real GCC compliance audits. Each one preventable.
Trap 01
Computing Transfer Pricing on incorrect wage base or taxable transaction value
Trap 02
Missing the statutory remittance deadline and incurring interest under Section 201(1A)
Trap 03
Submitting incorrect deductee PAN, resulting in TDS credit not reflecting in employee Form 26AS
Trap 04
Failing to file the quarterly statement on time, attracting Section 234E late fee
Done for you
Accounting and Tax
IRPR Network handles Transfer Pricing as part of our Accounting and Tax service, with timely filings, supporting-document validation, citation tracking, and a zero-penalty compliance calendar.
Our workflow
- 01Identify the trigger event in your GCC operations
- 02Prepare and validate the Transfer Pricing filing or compliance step
- 03Submit to the regulator and obtain acknowledgement
- 04Track in your compliance calendar for ongoing or recurring obligations
Concepts connected to Transfer Pricing
These terms are filed together, depend on each other, or share regulatory authority.
Income Tax and TDS
Form 3CEB
Chartered Accountant report certifying transfer pricing of international transactions between associated enterprises.
Income Tax and TDS
ITR-6
Annual income tax return form filed by every company other than those claiming exemption under Section 11.
FEMA and RBI
FLA Return
Annual RBI filing reporting foreign liabilities and assets of Indian companies; due 15 July each year.
Asked about Transfer Pricing
5 specific questions that GCC operators ask most often, answered with citations to the relevant regulations.
Need help with Transfer Pricing?
IRPR Network manages Transfer Pricing as part of Accounting and Tax, with a zero-penalty guarantee.
Explore the serviceQ01What is Transfer Pricing and who does it apply to?
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Tax rules requiring international transactions and specified domestic transactions between associated enterprises to be at arm's length price. For foreign-owned GCCs, Transfer Pricing applies to all indian employers and payers subject to tds. IRPR Network handles Transfer Pricing as part of our Accounting and Tax service.
Q02When is Transfer Pricing due?
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Transfer Pricing is due form 3ceb filed by 31 october with the income tax return. Late filing triggers section 271aa: 2 percent of value of international transaction for documentation failure; section 271ba: penalty of inr 1 lakh for failure to file form 3ceb.
Q03What law governs Transfer Pricing?
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Transfer Pricing is governed by Income Tax Act, 1961, specifically Sections 92 to 92F, read with Rules 10A to 10TG of Income Tax Rules, 1962. The compliance is enforced by Central Board of Direct Taxes (CBDT).
Q04What is the penalty for non-compliance with Transfer Pricing?
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Non-compliance attracts: Section 271AA: 2 percent of value of international transaction for documentation failure; Section 271BA: penalty of INR 1 lakh for failure to file Form 3CEB IRPR Network's compliance retainer is designed to prevent these exposures through proactive filing, citation tracking, and a defined compliance calendar.
Q05Who handles Transfer Pricing for foreign-owned GCCs in India?
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IRPR Network handles Transfer Pricing end-to-end as part of our Accounting and Tax service. Our team prepares filings, coordinates with regulators, validates supporting documents, and tracks all related deadlines on a defined compliance calendar.
Handle Transfer Pricing the right way, the first time.
Book a 30-minute consultation. We will map your Transfer Pricing obligations alongside every other India compliance for your GCC, on one calendar, one retainer.
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