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Transfer Pricing Documentation in India: What to Keep | NDSA
TP documentation · What to keep

If it isn’t documented, it didn’t happen.

Indian TP rules require records that show how prices were set, kept by the time the return is filed. Gaps can bring penalties and adjustments. Check your file.

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₹1 croreDocumentation threshold
Section 171New Act
Master fileFor larger groups
Is your file complete?

A guide only. We review the full file.

01 · Local file

What the Indian local file holds.

OwnershipGroup structure
BusinessProfile and history
BudgetsForecasts and plans
02 · Three tiers

Local file, master file and CbC report.

Local fileMaster fileCbC report
WhoAbove ₹1 crore of transactionsLarger groupsVery large groups
ContentIndian transactionsGroup overviewCountry data
FiledKept, produced on requestFiled in IndiaFiled by parent or in India
Aligned withForm 48OECD formatOECD format
03 · Penalties

Documentation gaps cost money.

Not kept

No documentation

A penalty linked to transaction value.

Not produced

Not furnished when asked

A separate penalty.

Weak

Thin evidence

Adjustments become likely.

04 · Common myths

Documentation myths.

Related services

More on transfer pricing.

Related pages.

Transfer pricing

TP disputes

Planning

Business compliance

Wherever you live in Europe

TP documentation across Europe.

We document TP for Indian entities of groups in every EU country, Switzerland and Norway.

BerlinMunichFrankfurtHamburgStuttgartAmsterdamRotterdamThe HagueEindhovenBrusselsAntwerpLuxembourgParisLyonToulouseDublinCorkStockholmGothenburgCopenhagenHelsinkiOsloZurichGenevaViennaMilanRomeMadridBarcelonaLisbonPortoWarsawKrakówPragueBudapestBucharestTallinnVilniusAthensValletta
05 · FAQs

TP documentation questions answered.

What must be documented?
Each international and specified transaction.
What is the threshold?
₹1 crore of international transactions.
When must it be ready?
By the return due date.
Which section now?
Section 171 of the new Act.
What is a master file?
Group-level documentation for larger groups.
What is a CbC report?
Country-by-country data for very large groups.
What if documents are missing?
Penalties and adjustments can follow.
Can HQ files be reused?
Partly; India needs local detail.
How long to keep it?
For several years.
Can you prepare ours?
Yes.

Gaps in your file? Let’s close them.

Share what you have. We’ll review and complete the documentation.

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General guidance based on the rules as they stand, including the Income-tax Act, 2025 and the Income-tax Rules, 2026. It is not legal, tax or financial advice for your situation; please contact us before acting on it.