Transfer Pricing Advisory & Documentation
Transfer pricing studies, benchmarking, Form 3CEB, master file and local file documentation, and APA and dispute support.
- Estimate Cost
- ₹50,000 – ₹5,00,000
- Typical duration
- 30 days
Service overview
Transfer pricing ensures that transactions between related parties, such as sales, services, royalties and loans, are priced at arm's length. Indian tax law requires annual documentation, benchmarking and certification to prevent profit shifting.
Who needs it? / When is it needed?
- Companies with international or specified domestic transactions with associated enterprises.
- Indian subsidiaries of foreign groups.
- Groups facing transfer pricing audits or seeking certainty through APAs.
What to expect from the WCP Professionals
- Functional, asset and risk analysis.
- Selection of the most appropriate method (TNMM, CUP and others).
- Benchmarking studies.
- Local File and Master File preparation.
- Form 3CEB certification.
- Inter-company agreements.
- APA, MAP and safe harbour support.
- Representation in audits and appeals.
Key deliverables
- Benchmarking report.
- TP study (Local File).
- Accountant's report in Form 3CEB.
- Inter-company agreements.
- Audit submissions.
Standard turnaround time
- TP study: 3–6 weeks.
- Form 3CEB generally due by 31 October.
- APA proceedings: 1–3 years.
Government fees, timelines & key outcomes
- No fee for Form 3CEB.
- APA filing fees range from Rs 10 lakh to Rs 20 lakh, based on transaction value.
- Penalty for not maintaining documentation can be 2% of the transaction value.
- Key outcome: defensible pricing and lower audit risk.
- Income-tax form and section references are under the Income-tax Act, 1961; for periods from 1 April 2026 WCP professionals use the corresponding provisions and forms of the Income-tax Act, 2025.
Forms & filings involved
- Form 3CEB (accountant's report).
- Form 3CEAA (Master File).
- Form 3CED (APA).
- Form 3CEFA (safe harbour).
- Form 34F (MAP).
Documents required
- Financial statements.
- Intercompany agreements and invoices.
- Group structure.
- Details of functions and risks.
- Previous TP studies and assessment orders.
What we need from you
- Access to management for functional interviews.
- Timely financial data.
- Consistent intercompany pricing.
Important conditions
- Documentation must be contemporaneous.
- Benchmarking data and methods may be challenged by tax officers.
- Secondary adjustments can apply.
Additional information
- Update benchmarking regularly.
- Related services: CbC Reporting, OECD BEPS Compliance, DTAA.
The estimated cost covers indicative professional fees only. Government fees, stamp duty and taxes are payable at actuals.
How it works
- 1. Raise a service enquiry describing your requirement.
- 2. A Relationship Manager reviews it and opens it for bidding.
- 3. Pay into escrow and assign the professional you select.
- 4. Track progress to completion, then accept and release payment.
Frequently asked questions
What is an arm's length price?
The price that unrelated parties would charge each other in similar circumstances, determined using prescribed methods.
What is Form 3CEB?
The accountant's report on international and specified domestic transactions, filed before the return due date.
What is an APA?
An Advance Pricing Agreement with the tax department that fixes the transfer pricing method for future years, giving certainty.
What penalties apply for non-compliance?
Penalties for failure to maintain or furnish documentation and for adjustments, which can be significant relative to transaction values.