TP Documentation · Panaji, Goa
Rigorous transfer pricing documentation — contemporaneous Local File, Master File (Form 3CEAA), Form 3CEB certification, and Country-by-Country Reporting (Form 3CEAD) by qualified CAs in Goa.
Overview
Section 92D of the Income Tax Act and Rule 10D require every taxpayer with international transactions to maintain contemporaneous transfer pricing documentation — in existence before the due date of filing the income tax return. BEPS Action 13, implemented in India through Rules 10DA and 10DB, added the three-tier documentation structure: Master File, Local File (TP study), and Country-by-Country Report (CbCR).
The TPO's first request in every TP audit is for the documentation package. A complete, accurate, and contemporaneous documentation set reduces the scope for adjustment, demonstrates good faith, and shifts the burden of proof. An incomplete or post-dated study invites penalties and gives the TPO grounds to propose its own ALP without reference to the taxpayer's analysis. Our TP study and benchmarking analysis services form the core of the documentation package.
What we cover
Master File, Local File, Form 3CEB, and CbCR — the complete Indian three-tier documentation structure.
Talk to our CA →The entity-level contemporaneous document covering each international transaction: functional analysis, transaction description, ALP method, benchmarking, and ALP conclusion. Must be maintained before ITR filing; retained for 9 years.
Group-level overview of the MNC's global business, value chain, transfer pricing policies, intangibles, intercompany financial arrangements, and global tax/financial data. Filed by 30 November by constituents of qualifying international groups (consolidated revenue ≥ ₹500 crore or Indian transactions ≥ ₹50 crore).
Granular jurisdiction-wise data on revenue, profit, tax paid, employees, capital, accumulated earnings, and activities for every jurisdiction in which the MNC group operates. Required for Indian reporting entities of groups with consolidated revenue ≥ ₹5,500 crore (≈USD 750 million). Filed by 31 March following the reporting accounting year.
The CA's certification of all international transactions and SDTs — disclosing the nature, parties, value, ALP method, and computed ALP for each transaction. Filed electronically by 31 October. Penalty for non-filing: ₹1 lakh under Section 271BA.
Legally enforceable intercompany agreements that correctly document the economic substance of each transaction — service agreements, IP licences, loan agreements, cost-sharing arrangements — reviewed for alignment with the TP documentation.
Advising on the 9-year retention obligation, annual updating of the Local File benchmarking search, and maintenance of contemporaneity — ensuring documents are dated and finalised before the ITR due date.
Documentation deadlines
Accountant's report on international transactions and SDTs — Section 92E. Penalty for late/non-filing: ₹1 lakh.
Group-level Master File for qualifying international groups. Rule 10DA.
Country-by-Country Report for qualifying Indian reporting entities of large MNC groups. Rule 10DB.
Contemporaneous TP study must exist before the ITR due date — cannot be prepared retrospectively.
Frequently asked questions
India implemented OECD BEPS Action 13's three-tier structure: (1) Local File — entity-level contemporaneous TP study per Rule 10D; (2) Master File (Form 3CEAA) — group-level MNC overview per Rule 10DA; and (3) Country-by-Country Report (Form 3CEAD) — jurisdiction-wise data for qualifying large MNC groups per Rule 10DB. Each tier has different eligibility thresholds and filing deadlines.
Rule 10D requires: enterprise overview and AE relationship description; nature of international transactions and AEs involved; description of functions, assets, and risks (FAR); record of controlled and uncontrolled comparable transactions; ALP determination methodology; ALP computed; and assumptions, policies, and price negotiations. All documents supporting these elements must be part of the contemporaneous record.
Every constituent entity of an international group in India must file Form 3CEAA if: (a) the group's consolidated revenue exceeds ₹500 crore in the reporting accounting year; or (b) the aggregate value of the entity's international transactions exceeds ₹50 crore; or (c) aggregate value of international transactions relating to intangibles exceeds ₹10 crore. Filed electronically by 30 November.
A parent entity of an international group resident in India must file Form 3CEAD if the group's consolidated revenue in the immediately preceding accounting year is ₹5,500 crore (approximately USD 750 million) or more. Indian subsidiary entities of foreign MNC groups file Form 3CEAC (CbCR notification) to inform the tax authority who the parent reporting entity is.
Section 271AA: 2% of the value of each international transaction or SDT for failure to maintain prescribed documentation, furnishing incorrect information, or not reporting a transaction. This penalty is in addition to the tax on any ALP adjustment. For Master File/CbCR non-compliance, penalty under Section 271GB applies — ₹5,000-15,000 per day for continued default.
A TP study is contemporaneous if it is prepared and in final form before the due date for filing the income tax return — 31 October for taxpayers subject to TP audit. It cannot be backdated or created after a TPO notice is received. TPOs routinely verify the date of preparation by examining file creation metadata, document headers, and whether the study references events that occurred after the claimed preparation date.
Related services
A complete, contemporaneous TP documentation package is your most powerful defence against a TPO adjustment. Our qualified CAs in Panaji, Goa will prepare your Local File, Master File, Form 3CEB, and CbCR — before your ITR deadline.