November 3, 2026
What Your Transfer Pricing Documentation Must Prove
A transfer pricing documentation file in India has one job: let a reviewer re-derive your price from the working you kept, without calling you. Section 92D obliges the taxpayer to keep that record. Rule 10D, in the Income-tax Rules, 1962, says what goes into it.
A draft study often arrives as a binder of four hundred pages, opening on group history, with the inventory risk question still unanswered by page ninety and a comparable table at the back that no search log supports. The reader is meant to accept all of it.
The rule comes first, clause by clause, because a draft that meets it is one you can sign. The four places a draft usually fails come after that: the functions analysis, the comparables set, the boundary with the group's master file and the date on the cover. Then the engagement letter, because the value of the study is in defending the price two years later.
Read the draft in front of you in the rule's order, and the gaps show up before the signature does.
Key takeaways
Rule 10D(1) lays out thirteen items, opening on the ownership structure at clause (a) and closing on a residual clause (m). Functions, risks and assets are described at clause (e).
Sub-rule (3) wants the analysis propped on authentic documents: publications of an official, technical or market-research kind, price data, published accounts, the agreements themselves, correspondence, and the records a practice normally issues.
The record should be contemporaneous where it can be, and it must be in existence when the specified date arrives, a date tied to the return-filing deadline.
Sub-rule (5) keeps the record for eight years, counted from the close of the assessment year (Rule 10D).
Where a deal runs over several years, fresh documentation is called for only if something changed that could move the price.
What transfer pricing documentation is in India, and what it is not
Transfer pricing documentation is the record a taxpayer keeps for its dealings with associated enterprises, and section 92D with Rule 10D sets what it holds. Its subject is the analysis behind the price, and sub-rule (3) expects authentic documents to stand behind that analysis. The taxpayer maintains the record and produces it when an officer calls for it.
Readers conflate three documents, and only one of them is the file. The first is the one above: the taxpayer's own record of the analysis, held under section 92D, produced on notice and filed nowhere.
The second is the form the accountant signs. The section 92E report, numbered Form 48 under the 2025 Act, is that signature placed on the file. What it certifies is the transactions and the prices; the analysis that supports them stays in the file itself. The change of form, and what it does to the filing season, is set out in our note on how Form 48 replaced Form 3CEB.
The third is the group layer: a master file and a CbC report, which a constituent entity of an international group maintains alongside its own file. Those two state the group's structure, where its intangibles sit, how it is financed and how its profit falls across jurisdictions. The file under Rule 10D states what this taxpayer's price is, and why.
A file that borrows the group's language without translating it into this entity's dealings leaves an officer with the group story and no price. The separation matters at the drafting stage, while the group material is still in a folder and easy to cut.
What gets asked before a study is commissioned
What is transfer pricing documentation?
It is the set of records a taxpayer with international dealings, or specified domestic ones, has to keep and maintain. Sub-rule (1) of Rule 10D lists the contents; sub-rule (4) fixes the date by which they must exist; sub-rule (5) fixes how long they stay.
What documentation is required for transfer pricing?
Thirteen items, and they run from the ownership structure and the group profile, through the terms and values of each deal and the analysis of functions and risks, past the forecasts, the outside transactions considered and the comparability work, to the method chosen, the working, the assumptions, the adjustment and a residual clause. Sub-rule (3) then asks for authentic documents in support.
What is a TP document?
TP documentation, or TP doc, is the shorthand practitioners use for the same Rule 10D file, and sometimes for the study that sits behind it. The contents matter more than the label: a document without the analysis and the arithmetic will not answer a notice.
Rule 10D's thirteen clauses, and the question each one answers
The sub-rule reaches every person who has an international transaction, or a specified domestic one, and tells that person to keep and maintain a set of information and documents it prescribes (the text of Rule 10D). Thirteen clauses follow, in an order worth noticing: identify the ownership and the counterparties, describe the business, describe the deals, then show the analysis and the arithmetic.
A draft that arrives in a different order is usually one assembled from last year's template, and the officer reads it in the rule's order whether the draft does or not.
Rule 10D(1) clause | The question a reviewer asks first | The document that answers it |
|---|---|---|
(a) Ownership and how it is held | Who owns this company, and through what? | Register of members and shareholding records |
(b) The group, and who sits on the other side | Which entity is the counterparty, and where is it taxed? | Group organisation chart and that company's statutory filings |
(c) What the business does, and its industry | What does this company do, and who competes with it? | Annual report and industry studies of the kind clause 10D(3)(b) names |
(d) Each deal, its terms, volume and price | What was transacted, in what volume, at what price? | Agreements, invoices and correspondence |
(e) What each side does, and what it risks | Who does the work, who carries the risk, who funds the assets? | The analysis and the contracts that allocate those risks |
(f) Forecasts, budgets and market analysis | Was the price set against a forecast, and did the year follow it? | Board papers, budgets and management accounts |
(g) Outside transactions that were looked at | Which outside companies were considered, and why these? | Database extracts and price publications |
(h) The comparability test | What was tested, and what was rejected? | The search log with its filters |
(i) Methods weighed, and the reason for the choice | Why this method for this deal? | The method note |
(j) The working, the data and the adjustments | Show the arithmetic. | The working paper and the published accounts of the comparables |
(k) Assumptions, policies and negotiations | What was assumed, and where is the negotiation record? | Correspondence and minutes |
(l) The adjustment booked, and its effect on income | Was the adjustment booked? | General ledger and the computation of income |
(m) Anything else that bears on the price | What else bears on this price? | Documents the accounting practice normally issues |
The table describes the file. The report the accountant signs is not one of its items, and the rule prescribes no form for the file itself.
Clauses (j) and (k) deserve more attention than a table can give them. Clause (j) asks for the working itself, which means the spreadsheet, the comparable data and every adjustment. Clause (k) asks for the assumptions, the policies and what was negotiated, wherever those things moved the price, and the group's correspondence on them belongs in the file.
Sub-rule (3) then asks that the information be supported by authentic documents, and the seven kinds it names are examples of what will do. The list is open. A file that cites the rule and carries none of those seven is a narrative.
Where the year's forms and dates matter more than the rule's shape, the India transfer pricing country profile sets the Indian position out to a stated legal cut-off.
The analysis of functions and risks is the spine of the study
Clause (e) asks the taxpayer to describe the functions it performs, the risks it assumes and the assets it employs, and to describe the same things for the associated enterprises on the other side. Every later clause leans on that description. It decides which entity is tested, which method fits that entity, and which companies can be compared with it.
Suppose a distributor in India buys finished goods from its parent, holds three months of stock and carries the credit risk on its customers. That company is not a routine buy-sell entity, and a comparable set drawn from commission agents will say nothing useful about its margin. Reverse one fact, so that the parent keeps the inventory while the Indian company sells on consignment. The same margin then has to be defended on a different argument.
A functions analysis of two pages cannot carry a study of four hundred pages. A reader who follows a margin back from the comparable table should arrive at the function that earned it: the stocking, the selling, the warranty, the receivable. Where the trail stops at a sentence saying the entity performs marketing and distribution functions, nothing in the file connects that work to a number.
Sub-rule (3), in its clause (e), puts evidence behind that description: contracts and agreements with group companies, and with unrelated parties for similar deals, appear on its list. An analysis claiming the Indian company carries no inventory risk, read against a purchase agreement that puts the loss on it, is the first thing an officer will read out.
The tested party follows from the same description. Pick the entity with the simpler functions where the facts support it, and the comparables get easier to find and easier to defend. Pick a company that carries risk it has no authority to manage, and every later choice has to explain the mismatch.
What fixes the number: the set, the window and the working
Clauses (g) to (j) carry the arithmetic, and they take the hardest editing when a deadline is close. What the rule wants is the outside transactions considered, the comparability work, the methods weighed with the reason for the one selected, and the working with its data and its adjustments. Section 92C governs how the chosen method reaches an arm's length price, and our note on section 165 against section 92C sets out where the 2025 Act moves the same questions.
The search window decides whether a comparables set survives an officer's reading. The file should show which databases were searched, which filters were applied, which companies came out, and which were then rejected and why. It should also show the financial year of the data each comparable contributes.
A set that mixes years without saying so cannot be reproduced by an officer, and a set that cannot be reproduced gets replaced by one that can.
Clause (g) wants the outside transactions that were considered, and the ones rejected need recording beside them. An officer who finds a comparable in a public database that the study never mentions will ask why it was left out, and the answer holds only if the search that missed it is documented.
A result inside the tolerance band still leaves the set to be tested. The band is a notified margin around the mean of the comparables, and the officer can test whether the set behind that mean is the right one. The working paper, not the conclusion, makes that test answerable.
Clause (l) then asks for the adjustment made to the prices and to total income, and that adjustment brings the study into the books. A study that concludes a margin the accounts do not carry has a problem the file cannot solve.
Where the local file stops and the master file begins
The three documents answer different questions, and the boundary between them is substantive. The Rule 10D file is about this taxpayer and these deals. The master file is about the group: its structure, its intangibles, its financing and its position as a whole. The CbC report is about the group's profit, people, assets and activity, jurisdiction by jurisdiction.
Document | The question it answers | What it describes |
|---|---|---|
Local file, Rule 10D | What is this taxpayer's price, and how was it reached? | This entity and its dealings |
Master file, Rule 10DA | How is the group organised, where do the intangibles sit, and how is it financed? | The international group |
CbC report, section 286 and Rule 10DB | Where does profit arise, and does it follow people, assets and activity? | The group, jurisdiction by jurisdiction |
Whether the group layer applies turns on the group and on the year. The tests sit in Rules 10DA and 10DB, and in section 286, and they are re-checked annually. Our note on why the CbC report must tell a single story deals with the return itself.
A master file does not prove a price, and a local file that copies the group's narrative has stopped doing its own work.
The test for where a passage belongs is easy to apply: it stays in the local file when it changes the analysis of this entity's dealings, or when it evidences a term of one of them. Forty pages of group history with no transaction in them belong in the master file.
Contemporaneity, and what existing means after the year closes
Sub-rule (4) asks for records that are contemporaneous so far as that is achievable, and that are in existence by the specified date, which clause (iv) of section 92F defines (the text of Rule 10D). That definition ties the date to the deadline for filing the return, as Explanation 2 to section 139(1) sets it (section 92F). Because the test is a date in the filing calendar for the year, a study commissioned after the year closes can still meet it.
A file finished after that date is one that did not exist when the rule says it had to. Nothing in the quality of the analysis repairs that, and the date is the first thing a reviewer can check without reading a page.
The proviso to the sub-rule relieves the taxpayer where a deal runs over more than one previous year. Documentation is refreshed only where something that could move the price has changed: the terms of the deal, the assumptions made, or another factor capable of influencing the transfer price. Where such a change happened, the fresh documentation has to bring out its effect on the price. A renewal can be tested on that basis: where the study is last year's with new figures, it should say why nothing significant changed.
Sub-rule (5) then fixes how long the material stays: eight years after the close of the assessment year it relates to (the text of Rule 10D). That is the life the evidence file has to have, and the database extracts and the correspondence are inside it, which are the parts most easily lost when a firm changes its document system.
What a tax head has to be able to show is a chain rather than a document: a dated draft, the date the analysis was completed, and the version that became the file. Where the analysis was commissioned late, the honest record is a late file, and an engagement letter that plans the refresh costs less than a reconstruction.
What to insist on in the engagement letter
An engagement letter settles what the study will contain long before any draft arrives. Each ask below costs nothing at the drafting stage and is expensive to reconstruct afterwards, and every one of them answers a clause of the rule.
The working papers behind the comparable set, not only the table: the search log, the filters, the rejected companies and the financials used for each comparable. That is what clauses (g) to (j) ask for, and it is the first thing an officer tests.
The evidence bundle sub-rule (3) describes, indexed as one file. Seven kinds of document appear on its list, and a draft usually carries two of them.
The dated draft trail, so the file's existence by the specified date can be shown with dates instead of assurances.
Sign-off by the person who will sit through the assessment, named, with the date they read the analysis. Our note on how the TPO submission shapes litigation is the long version of that point.
The refresh trigger, written down: what the firm and the company will treat as a significant change under the proviso to sub-rule (4), who decides, and when in the year that decision is taken.
Hand-over of the analysis itself: the functions note as editable text, the comparable spreadsheet with its formulas, and the index to the correspondence.
None of these asks the firm to work differently; they ask it to hand over what it already produced. A letter that names them turns the deliverable from a binder into a file.
A five-minute test before you sign the study
Take a draft that is ready for signature and read it in one order. Each test below takes a minute, and each one checks a different clause.
Open at clause (e). If the analysis of functions, risks and assets is not findable in the first ten pages, the study was assembled from a template and the number at the back has no support.
Pick one margin from the comparable table and follow it back. You should reach a working that names the comparable, the year of its data and the adjustment made. Where the trail ends at a conclusion, the file does not exist yet.
Find the authentic document behind that analysis: the purchase agreement, the service contract, or the correspondence that fixed the price. The rule expects it, and the officer will ask for it before asking about the margin.
Read the date on the file and set it against the specified date for the year. A file finished after that date, however good the analysis, answers a different question from the one the rule asks.
A study that survives those four checks is doing what the rule asks of it: it evidences a price, dated, documented and reproducible. One that does not is still a binder, and the season for discovering that is not the month before the report is due.
This note rests on section 92D, on Rule 10D sub-rules (1), (3), (4) and (5), on section 92E and on clause (iv) of section 92F. The position was checked on 3 November 2026.
If you are holding a draft now and want it read against these clauses before it is signed, contact us, and we will go through it with you.
A transfer pricing documentation file in India has one job: let a reviewer re-derive your price from the working you kept, without calling you. Section 92D obliges the taxpayer to keep that record. Rule 10D, in the Income-tax Rules, 1962, says what goes into it.
A draft study often arrives as a binder of four hundred pages, opening on group history, with the inventory risk question still unanswered by page ninety and a comparable table at the back that no search log supports. The reader is meant to accept all of it.
The rule comes first, clause by clause, because a draft that meets it is one you can sign. The four places a draft usually fails come after that: the functions analysis, the comparables set, the boundary with the group's master file and the date on the cover. Then the engagement letter, because the value of the study is in defending the price two years later.
Read the draft in front of you in the rule's order, and the gaps show up before the signature does.
Key takeaways
Rule 10D(1) lays out thirteen items, opening on the ownership structure at clause (a) and closing on a residual clause (m). Functions, risks and assets are described at clause (e).
Sub-rule (3) wants the analysis propped on authentic documents: publications of an official, technical or market-research kind, price data, published accounts, the agreements themselves, correspondence, and the records a practice normally issues.
The record should be contemporaneous where it can be, and it must be in existence when the specified date arrives, a date tied to the return-filing deadline.
Sub-rule (5) keeps the record for eight years, counted from the close of the assessment year (Rule 10D).
Where a deal runs over several years, fresh documentation is called for only if something changed that could move the price.
What transfer pricing documentation is in India, and what it is not
Transfer pricing documentation is the record a taxpayer keeps for its dealings with associated enterprises, and section 92D with Rule 10D sets what it holds. Its subject is the analysis behind the price, and sub-rule (3) expects authentic documents to stand behind that analysis. The taxpayer maintains the record and produces it when an officer calls for it.
Readers conflate three documents, and only one of them is the file. The first is the one above: the taxpayer's own record of the analysis, held under section 92D, produced on notice and filed nowhere.
The second is the form the accountant signs. The section 92E report, numbered Form 48 under the 2025 Act, is that signature placed on the file. What it certifies is the transactions and the prices; the analysis that supports them stays in the file itself. The change of form, and what it does to the filing season, is set out in our note on how Form 48 replaced Form 3CEB.
The third is the group layer: a master file and a CbC report, which a constituent entity of an international group maintains alongside its own file. Those two state the group's structure, where its intangibles sit, how it is financed and how its profit falls across jurisdictions. The file under Rule 10D states what this taxpayer's price is, and why.
A file that borrows the group's language without translating it into this entity's dealings leaves an officer with the group story and no price. The separation matters at the drafting stage, while the group material is still in a folder and easy to cut.
What gets asked before a study is commissioned
What is transfer pricing documentation?
It is the set of records a taxpayer with international dealings, or specified domestic ones, has to keep and maintain. Sub-rule (1) of Rule 10D lists the contents; sub-rule (4) fixes the date by which they must exist; sub-rule (5) fixes how long they stay.
What documentation is required for transfer pricing?
Thirteen items, and they run from the ownership structure and the group profile, through the terms and values of each deal and the analysis of functions and risks, past the forecasts, the outside transactions considered and the comparability work, to the method chosen, the working, the assumptions, the adjustment and a residual clause. Sub-rule (3) then asks for authentic documents in support.
What is a TP document?
TP documentation, or TP doc, is the shorthand practitioners use for the same Rule 10D file, and sometimes for the study that sits behind it. The contents matter more than the label: a document without the analysis and the arithmetic will not answer a notice.
Rule 10D's thirteen clauses, and the question each one answers
The sub-rule reaches every person who has an international transaction, or a specified domestic one, and tells that person to keep and maintain a set of information and documents it prescribes (the text of Rule 10D). Thirteen clauses follow, in an order worth noticing: identify the ownership and the counterparties, describe the business, describe the deals, then show the analysis and the arithmetic.
A draft that arrives in a different order is usually one assembled from last year's template, and the officer reads it in the rule's order whether the draft does or not.
Rule 10D(1) clause | The question a reviewer asks first | The document that answers it |
|---|---|---|
(a) Ownership and how it is held | Who owns this company, and through what? | Register of members and shareholding records |
(b) The group, and who sits on the other side | Which entity is the counterparty, and where is it taxed? | Group organisation chart and that company's statutory filings |
(c) What the business does, and its industry | What does this company do, and who competes with it? | Annual report and industry studies of the kind clause 10D(3)(b) names |
(d) Each deal, its terms, volume and price | What was transacted, in what volume, at what price? | Agreements, invoices and correspondence |
(e) What each side does, and what it risks | Who does the work, who carries the risk, who funds the assets? | The analysis and the contracts that allocate those risks |
(f) Forecasts, budgets and market analysis | Was the price set against a forecast, and did the year follow it? | Board papers, budgets and management accounts |
(g) Outside transactions that were looked at | Which outside companies were considered, and why these? | Database extracts and price publications |
(h) The comparability test | What was tested, and what was rejected? | The search log with its filters |
(i) Methods weighed, and the reason for the choice | Why this method for this deal? | The method note |
(j) The working, the data and the adjustments | Show the arithmetic. | The working paper and the published accounts of the comparables |
(k) Assumptions, policies and negotiations | What was assumed, and where is the negotiation record? | Correspondence and minutes |
(l) The adjustment booked, and its effect on income | Was the adjustment booked? | General ledger and the computation of income |
(m) Anything else that bears on the price | What else bears on this price? | Documents the accounting practice normally issues |
The table describes the file. The report the accountant signs is not one of its items, and the rule prescribes no form for the file itself.
Clauses (j) and (k) deserve more attention than a table can give them. Clause (j) asks for the working itself, which means the spreadsheet, the comparable data and every adjustment. Clause (k) asks for the assumptions, the policies and what was negotiated, wherever those things moved the price, and the group's correspondence on them belongs in the file.
Sub-rule (3) then asks that the information be supported by authentic documents, and the seven kinds it names are examples of what will do. The list is open. A file that cites the rule and carries none of those seven is a narrative.
Where the year's forms and dates matter more than the rule's shape, the India transfer pricing country profile sets the Indian position out to a stated legal cut-off.
The analysis of functions and risks is the spine of the study
Clause (e) asks the taxpayer to describe the functions it performs, the risks it assumes and the assets it employs, and to describe the same things for the associated enterprises on the other side. Every later clause leans on that description. It decides which entity is tested, which method fits that entity, and which companies can be compared with it.
Suppose a distributor in India buys finished goods from its parent, holds three months of stock and carries the credit risk on its customers. That company is not a routine buy-sell entity, and a comparable set drawn from commission agents will say nothing useful about its margin. Reverse one fact, so that the parent keeps the inventory while the Indian company sells on consignment. The same margin then has to be defended on a different argument.
A functions analysis of two pages cannot carry a study of four hundred pages. A reader who follows a margin back from the comparable table should arrive at the function that earned it: the stocking, the selling, the warranty, the receivable. Where the trail stops at a sentence saying the entity performs marketing and distribution functions, nothing in the file connects that work to a number.
Sub-rule (3), in its clause (e), puts evidence behind that description: contracts and agreements with group companies, and with unrelated parties for similar deals, appear on its list. An analysis claiming the Indian company carries no inventory risk, read against a purchase agreement that puts the loss on it, is the first thing an officer will read out.
The tested party follows from the same description. Pick the entity with the simpler functions where the facts support it, and the comparables get easier to find and easier to defend. Pick a company that carries risk it has no authority to manage, and every later choice has to explain the mismatch.
What fixes the number: the set, the window and the working
Clauses (g) to (j) carry the arithmetic, and they take the hardest editing when a deadline is close. What the rule wants is the outside transactions considered, the comparability work, the methods weighed with the reason for the one selected, and the working with its data and its adjustments. Section 92C governs how the chosen method reaches an arm's length price, and our note on section 165 against section 92C sets out where the 2025 Act moves the same questions.
The search window decides whether a comparables set survives an officer's reading. The file should show which databases were searched, which filters were applied, which companies came out, and which were then rejected and why. It should also show the financial year of the data each comparable contributes.
A set that mixes years without saying so cannot be reproduced by an officer, and a set that cannot be reproduced gets replaced by one that can.
Clause (g) wants the outside transactions that were considered, and the ones rejected need recording beside them. An officer who finds a comparable in a public database that the study never mentions will ask why it was left out, and the answer holds only if the search that missed it is documented.
A result inside the tolerance band still leaves the set to be tested. The band is a notified margin around the mean of the comparables, and the officer can test whether the set behind that mean is the right one. The working paper, not the conclusion, makes that test answerable.
Clause (l) then asks for the adjustment made to the prices and to total income, and that adjustment brings the study into the books. A study that concludes a margin the accounts do not carry has a problem the file cannot solve.
Where the local file stops and the master file begins
The three documents answer different questions, and the boundary between them is substantive. The Rule 10D file is about this taxpayer and these deals. The master file is about the group: its structure, its intangibles, its financing and its position as a whole. The CbC report is about the group's profit, people, assets and activity, jurisdiction by jurisdiction.
Document | The question it answers | What it describes |
|---|---|---|
Local file, Rule 10D | What is this taxpayer's price, and how was it reached? | This entity and its dealings |
Master file, Rule 10DA | How is the group organised, where do the intangibles sit, and how is it financed? | The international group |
CbC report, section 286 and Rule 10DB | Where does profit arise, and does it follow people, assets and activity? | The group, jurisdiction by jurisdiction |
Whether the group layer applies turns on the group and on the year. The tests sit in Rules 10DA and 10DB, and in section 286, and they are re-checked annually. Our note on why the CbC report must tell a single story deals with the return itself.
A master file does not prove a price, and a local file that copies the group's narrative has stopped doing its own work.
The test for where a passage belongs is easy to apply: it stays in the local file when it changes the analysis of this entity's dealings, or when it evidences a term of one of them. Forty pages of group history with no transaction in them belong in the master file.
Contemporaneity, and what existing means after the year closes
Sub-rule (4) asks for records that are contemporaneous so far as that is achievable, and that are in existence by the specified date, which clause (iv) of section 92F defines (the text of Rule 10D). That definition ties the date to the deadline for filing the return, as Explanation 2 to section 139(1) sets it (section 92F). Because the test is a date in the filing calendar for the year, a study commissioned after the year closes can still meet it.
A file finished after that date is one that did not exist when the rule says it had to. Nothing in the quality of the analysis repairs that, and the date is the first thing a reviewer can check without reading a page.
The proviso to the sub-rule relieves the taxpayer where a deal runs over more than one previous year. Documentation is refreshed only where something that could move the price has changed: the terms of the deal, the assumptions made, or another factor capable of influencing the transfer price. Where such a change happened, the fresh documentation has to bring out its effect on the price. A renewal can be tested on that basis: where the study is last year's with new figures, it should say why nothing significant changed.
Sub-rule (5) then fixes how long the material stays: eight years after the close of the assessment year it relates to (the text of Rule 10D). That is the life the evidence file has to have, and the database extracts and the correspondence are inside it, which are the parts most easily lost when a firm changes its document system.
What a tax head has to be able to show is a chain rather than a document: a dated draft, the date the analysis was completed, and the version that became the file. Where the analysis was commissioned late, the honest record is a late file, and an engagement letter that plans the refresh costs less than a reconstruction.
What to insist on in the engagement letter
An engagement letter settles what the study will contain long before any draft arrives. Each ask below costs nothing at the drafting stage and is expensive to reconstruct afterwards, and every one of them answers a clause of the rule.
The working papers behind the comparable set, not only the table: the search log, the filters, the rejected companies and the financials used for each comparable. That is what clauses (g) to (j) ask for, and it is the first thing an officer tests.
The evidence bundle sub-rule (3) describes, indexed as one file. Seven kinds of document appear on its list, and a draft usually carries two of them.
The dated draft trail, so the file's existence by the specified date can be shown with dates instead of assurances.
Sign-off by the person who will sit through the assessment, named, with the date they read the analysis. Our note on how the TPO submission shapes litigation is the long version of that point.
The refresh trigger, written down: what the firm and the company will treat as a significant change under the proviso to sub-rule (4), who decides, and when in the year that decision is taken.
Hand-over of the analysis itself: the functions note as editable text, the comparable spreadsheet with its formulas, and the index to the correspondence.
None of these asks the firm to work differently; they ask it to hand over what it already produced. A letter that names them turns the deliverable from a binder into a file.
A five-minute test before you sign the study
Take a draft that is ready for signature and read it in one order. Each test below takes a minute, and each one checks a different clause.
Open at clause (e). If the analysis of functions, risks and assets is not findable in the first ten pages, the study was assembled from a template and the number at the back has no support.
Pick one margin from the comparable table and follow it back. You should reach a working that names the comparable, the year of its data and the adjustment made. Where the trail ends at a conclusion, the file does not exist yet.
Find the authentic document behind that analysis: the purchase agreement, the service contract, or the correspondence that fixed the price. The rule expects it, and the officer will ask for it before asking about the margin.
Read the date on the file and set it against the specified date for the year. A file finished after that date, however good the analysis, answers a different question from the one the rule asks.
A study that survives those four checks is doing what the rule asks of it: it evidences a price, dated, documented and reproducible. One that does not is still a binder, and the season for discovering that is not the month before the report is due.
This note rests on section 92D, on Rule 10D sub-rules (1), (3), (4) and (5), on section 92E and on clause (iv) of section 92F. The position was checked on 3 November 2026.
If you are holding a draft now and want it read against these clauses before it is signed, contact us, and we will go through it with you.
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If you are evaluating cross-border expansion, restructuring, or strengthening compliance and audit readiness, we can help you plan and execute with clarity.