Sections 92–92F · Rules 10A–10THD
Every cross-border transaction with an associated enterprise must meet the arm's length standard — and the resulting pricing drives what you may lawfully remit under FEMA. We handle both sides together.
Form 3CEB is due 31 October; Master File applies above ₹500 crore group revenue with ₹50 crore of international transactions, and CbCR at €750 million consolidated group revenue.
Practical transfer pricing notes for groups managing intercompany pricing, documentation and cross-border remittances.
Documentation
The commercial story, functional analysis, method selection and comparables that allow a reviewer to follow the arm’s-length conclusion.
Key takeaway: The strongest study connects the numbers to how the business actually operates.
FEMA overlap
Why pricing, invoices, remittances, agreements and reporting should be reviewed together for related-party cross-border services.
Key takeaway: Tax benchmarking does not replace an exchange-control review of the payment route.
Certainty
The practical signals that recurring, material or complex transactions may justify investing in advance certainty rather than repeating disputes.
Key takeaway: Model the cost of uncertainty over the full expected life of the transaction.
