TP Country Profile
India Transfer Pricing Country Profile
Legal framework, pricing methods, documentation, reporting and dispute routes for FY 2025–26 and Tax Year 2026–27, with a legal cut-off of 15 October 2026.
Edition 1.0
Legal cut-off: 15 October 2026
FY 2025–26 / AY 2026–27 (legacy regime); Tax Year 2026–27 (new regime)
India transfer pricing in brief
India requires international transactions between associated enterprises, and specified domestic transactions, to be priced at arm’s length. From 1 April 2026 the rules sit in Chapter X of the Income-tax Act, 2025 and the Income-tax Rules, 2026. FY 2025–26 (AY 2026–27) stays under the Income-tax Act, 1961. The annual accountant’s report is Form 48 under the new law and Form 3CEB for FY 2025–26.
India transfer pricing at a glance
Topic | Headline position |
|---|---|
Law | Income-tax Act, 2025 (Chapter X) and Income-tax Rules, 2026 from 1 April 2026; Income-tax Act, 1961 for FY 2025–26 |
Covers | International transactions between associated enterprises, and specified domestic transactions above ₹20 crore |
Methods | CUP, resale price, cost plus, profit split, TNMM and the prescribed “other” method |
Annual report | Form 48 under the new law; Form 3CEB for FY 2025–26 |
Records | Domestic documentation kept and produced on requisition; Master File (Form 56); country-by-country report (Forms 58–60) |
Group reports | Full Master File where group revenue exceeds ₹500 crore and the transaction test is met; country-by-country report where prior-year group revenue exceeds ₹6,400 crore |
Disputes | Advance Pricing Agreements, Mutual Agreement Procedure, Dispute Resolution Panel and appeals |
What the full profile covers
The full 24-page profile includes:
Legal framework, associated enterprises and coverage tests
Methods and benchmarking
Documentation, Master File, country-by-country reporting and accountant certification
Transaction-specific rules, permanent-establishment attribution and safe harbours
Implementation, year-end and secondary adjustments
Audit, penalties and limitation
Advance Pricing Agreements, Mutual Agreement Procedure, appeals
Current developments and practical priorities
Download the full profile for the filing deadlines, safe-harbour rates, penalty tables and case law.
Frequently asked questions
What is transfer pricing in India?
Transfer pricing in India requires transactions between associated enterprises, including specified domestic transactions, to be priced at arm’s length. The rules sit in Chapter X of the Income-tax Act, 2025 for Tax Year 2026–27 and in the Income-tax Act, 1961 for FY 2025–26.
Which law governs transfer pricing in India in 2026?
From 1 April 2026, Chapter X of the Income-tax Act, 2025 and the Income-tax Rules, 2026 govern transfer pricing. FY 2025–26 (AY 2026–27) continues under the Income-tax Act, 1961 and its rules.
Which form is the transfer pricing accountant’s report in India?
Under the Income-tax Act, 2025 the accountant’s report is Form 48. For FY 2025–26 the legacy Form 3CEB applies. It is an annual obligation, not just a study to produce on request.
Do I have to file a Local File in India?
India does not simply require an OECD-style Local File filing. Section 171 and Rule 84 require transaction-level documentation that the taxpayer maintains and produces on requisition. It is not filed annually, but the Master File and country-by-country report have their own filing rules.
What are the transfer pricing dispute options in India?
Taxpayers can seek an Advance Pricing Agreement (unilateral, bilateral or multilateral, covering up to five years with rollback of up to four prior years), use the Mutual Agreement Procedure under the applicable tax treaty, or follow the domestic route through the Dispute Resolution Panel and appeals.
Where can I get the full India transfer pricing profile?
Download the 24-page India Transfer Pricing Country Profile (Edition 1.0, legal cut-off 15 October 2026). It covers thresholds, filing deadlines, safe-harbour rates, penalties and case law in detail.
Related services
Prepared by AventaaGlobal Advisors LLP. Edition 1.0, legal cut-off 15 October 2026. This summary is for general information and is not legal or tax advice.