Transfer Pricing Report



Transfer Pricing Report As per The Income Tax Act, 1961.

What is Transfer Pricing?

  • Transfer pricing refers to the setting, analysis, documentation, and adjustment of charges made between related parties for goods, services, or use of property (including intangible property).

Is Transfer Pricing Report mandatory?

  • Yes, Companies having international transaction with Associated Enterprises and having Turnover more than Rs 500 Lakhs for a financial year come under this mandate.
  • Section 92 to 92F of the Income Tax Act 1961 governs the TP in Indian context

About New amendment Section 92

  • The Finance Act, 2001 substituted Section 92 of the Income Tax Act, 1961 by new sections 92 and 92A to 92F. These new provisions require commercial outcomes arising from international transactions between associated enterprises to be consistent with the arm’s length principle.
  • The calculation of arm’s length price has to be done by using the most appropriate method. Income Tax Act mandates the company that ALP is to be calculated using one of the following methods:
  • Comparable Uncontrolled Price method (“CUP”)
  • Resale Price Method (“RPM”)
  • Cost Plus Method (“CPLM”)
  • Profit Split Method (“PSM”)
  • Transactional Net Margin Method (“TNMM”)

Poweress™ & Capitaline Plus™

  • Poweress™ & Capitaline Plus™ Databases are available in India to compare the results of a company with other companies to determine ALP.

Certification of the Transfer Pricing Report

  • As per Income Tax Act companies who are required to file TP reports has to file FORM 3CEB to the Tax department duly certified by a Chartered Accountant.
  • The Certification emphasizes on the Analysis of the following Aspects:
  • Functional Analysis
  • Risk Analysis
  • Economical Analysis

Why consulting from us?

  • We provide full strength professional services on activities relating to Transfer Pricing as according to ALP pronounced by the prescribed authorities in this respect. We assist you in the following aspects of Transfer Pricing :
  • Planning, Review & Evaluation of Transfer Pricing Mechanism.
  • Adherences and Compliance of Transfer Pricing Regulations and Provisions as according with present Legislations.
  • Representation before the competent authorities.
  • Expert tax planning with a flexible approach on implementation of methodologies of transfer pricing.
  • Consultancy services on Potential threats interrelated with the existing legislation and the policies of the organization to avoid Taxation & legal Consequences.