Transfer Pricing Documentation & Advisory
Arm's Length Price studies, Form 3CEB certification, Master File, Local File, Country-by-Country Reporting, and APA applications — for companies with international related-party transactions.
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200+
TP Studies delivered
Nov 30
Form 3CEB deadline — never missed
BEPS Action 13
Compliant documentation
100% On-Time
Form 3CEB filings
What is Transfer Pricing?
Transfer pricing regulates the pricing of transactions between related parties (associated enterprises or AEs). In India, governed by Sections 92 to 92F of the Income Tax Act 1961. Applies to: international transactions between AEs exceeding ₹1 crore, and specified domestic transactions exceeding ₹20 crore. The Arm's Length Price (ALP) must be determined using TNMM, CUP, RPM, CPM, or PSM methods.
Form 3CEB — a CA-certified report — must be filed with the ITR by November 30. Non-compliance: penalty of 2% of transaction value.
Penalty for non-maintenance of TP documentation: 2% of transaction value. Penalty for an incorrect TP report: 2% of transaction value. Income additions by the TP Officer are taxed as business income with interest under 234B/C.
TP applicability
International transactions between AEs > ₹1 crore
Form 3CEB deadline
November 30 of assessment year
Domestic TP threshold
Specified domestic transactions > ₹20 crore
CBCR threshold
Consolidated revenue > ₹5,500 crore
ALP methods
TNMM, CUP, RPM, CPM, PSM
What JCA Delivers for Transfer Pricing
Form 3CEB Before Deadline
CA-certified Form 3CEB delivered before November 30 deadline every year — including benchmarking analysis and functional profile.
Complete TP Documentation
Master File, Local File, and CbCR filings prepared and maintained in accordance with OECD guidelines and Indian TP Rules.
Benchmark Database Access
Access to Prowess IQ, Bureau van Dijk (BvD), and global databases for robust ALP comparables — defensible in tax authority scrutiny.
International Transaction Coverage
Intragroup services, goods transactions, IP licensing, financial transactions (back-to-back loans, guarantees), and cost-sharing arrangements.
APA Advisory
Advance Pricing Agreement (APA) applications — bilateral and unilateral — to bring certainty on pricing for 5 future years.
TP Litigation Support
DRP representation, ITAT appeals, MAP/mutual agreement procedures — JCA supports through all levels of dispute resolution.
How We Prepare Your TP Documentation
Functional analysis through Form 3CEB filing — a structured five-step methodology.
Functional Analysis (FAR)
Conduct functional, asset, and risk (FAR) analysis interviews; document functions performed, assets used, and risks assumed by each AE; identify characterisation.
Transaction Identification & Categorisation
Identify all international transactions (goods, services, royalties, loans, guarantees); categorise by type; determine applicable TP method for each category.
Benchmarking & ALP Determination
Search comparables from Prowess IQ / BvD databases; apply TNMM, CUP, or other method; compute ALP range; confirm transactions fall within acceptable range.
Documentation Preparation
Prepare Local File (transaction-level TP documentation); Master File (group overview, value chain analysis); CBCR (if applicable); economic analysis and policy.
Form 3CEB Filing
CA certifies Form 3CEB covering all specified domestic and international transactions; file before November 30 deadline; retain documentation for 8 years.
Documents Required
Group & Transaction Information
- Group organisational chart and shareholding structure
- Intercompany agreements (services, licensing, loans, guarantees)
- Annual reports and financials of AEs (last 2 years)
- Functional profile questionnaire (completed by management)
- Details of all international transactions with AEs
Prior Documentation
- Prior year Form 3CEB and TP documentation
- Transfer pricing policy document (if any)
- Cost allocation methodologies used
- Royalty / IP valuation reports (if applicable)
- APA letter (if APA exists with any country)
Why Choose Juris Capital Advisory
for Transfer Pricing?
Form 3CEB On Time
Every Form 3CEB delivered before November 30 — no deadline extensions requested, no last-minute filings.
Robust Comparables
Benchmarking using Prowess IQ and Bureau van Dijk — quality comparables that withstand TP Officer scrutiny.
All Transaction Types
Intragroup services, goods, IP licensing, back-to-back loans, guarantees, cost-sharing — all covered.
BEPS Aligned
Documentation aligned with OECD BEPS Action 13 — Master File, Local File, and CBCR where applicable.
APA Experience
Advance Pricing Agreement advisory — bringing 5-year pricing certainty and eliminating annual TP risk.
Litigation Through ITAT
DRP submissions, ITAT TP appeals, and MAP procedures — represented at all dispute resolution forums.
What Our Clients Say
“Our TP documentation covered intragroup IT services, a back-to-back loan, and IP licensing — three different methods. JCA delivered Form 3CEB and the full TP study 3 weeks before the deadline. Zero additions by the TP Officer.”
Deepak Venkataraman
Group CFO, IT Services MNC, Bangalore
“We had a pending TP dispute at ITAT for AY 2019-20 involving a significant addition. JCA prepared the written submissions, argued the economic analysis, and obtained a full deletion of the addition.”
Chandrika Krishnaswamy
VP Finance, Pharma Company, Hyderabad
“JCA prepared our CBCR, Master File, and Local File for the first time. They interviewed 6 global entities, mapped the value chain, and delivered compliant BEPS-aligned documentation.”
Harish Balaji
Head Tax, Global Manufacturing Group, Chennai