Regulatory Framework · India
Transfer Pricing Lawyer in India
Transfer pricing disputes are the most expensive tax controversy in India. Manage them proactively.
100+
TP Matters
₹500Cr+
TP Adjustments Contested
5
APA Applications
Understanding the Regulatory Framework
Transfer pricing — the pricing of cross-border transactions between associated enterprises — is the most contested area of Indian corporate tax law. The Indian income tax authorities have historically adopted aggressive positions in TP assessments, leading to large adjustments and significant litigation. The Income Tax Act 1961 requires that international transactions between associated enterprises be at arm's length, with comprehensive documentation. Corpus Juris Legal advises multinational companies and their Indian subsidiaries on TP documentation, Advance Pricing Agreements (APAs), Safe Harbour elections, and representation in Dispute Resolution Panel (DRP) and ITAT proceedings.
Transfer pricing documentation — Local File, Master File, CbCR
Advance Pricing Agreement (APA) application and negotiation with CBDT
Safe Harbour rule compliance for eligible categories
TP assessment response and Dispute Resolution Panel (DRP) representation
ITAT transfer pricing appeals — Delhi Bench
Mutual Agreement Procedure (MAP) advisory
Frequently Asked Questions
What TP documentation is required for Indian companies with cross-border intercompany transactions?+
For international transactions exceeding ₹1 crore, the Indian entity must maintain a TP study (Local File) prepared before the tax return due date, supported by a Chartered Accountant's Form 3CEB. Companies with consolidated revenue above ₹500 crore must also maintain a Master File and file Country-by-Country Reporting (CbCR) if the group's consolidated revenue exceeds ₹5,500 crore.
What is an Advance Pricing Agreement (APA) and should we apply for one?+
An APA is a formal agreement between a taxpayer and the Indian tax authority (CBDT) on the transfer pricing methodology and arm's length price for specified future transactions. APAs provide certainty for 5 years (bilateral APAs up to 9 years including rollback). They are strongly advisable for companies with large or recurring intercompany transactions.
What are Safe Harbour rules for transfer pricing in India?+
Safe Harbour rules specify conditions under which the Indian tax authorities will accept the declared transfer price without scrutiny. They apply to specific categories of services (IT, ITES, KPO, intra-group loans, guarantees) up to specified revenue thresholds. The mark-up rates specified are higher than arm's length in some cases, so Safe Harbour is not always the optimal election.
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