Transfer Pricing Compliance Timelines
As the Indian financial Year 2024-25 has come to an end, it is time for the Indian taxpayers to concentrate on the year end compliances and filings.
VSTN has compiled a document outlining the various timelines for Indian Transfer Pricing Compliances for the benefit of readers.
TRANSFER PRICING COMPLIANCE TIMELINES
Compliance | Section under Indian Income-tax Act, 1961 | Form Number | Applicability | Due Date | Penalty for non-compliance |
---|---|---|---|---|---|
Transfer Pricing Certificate | 92E | 3CEB |
|
31-Oct-2025 | INR 1,00,000/- |
Transfer Pricing Documentation | 92D | – |
|
31-Oct-2025 | 2% of value of international transactions |
Master File (One pager form) | 92D (4) | 3CEAA (Part A) | All the Indian entities part of Multinational Group Irrespective of applicability of TP | 30-Nov-2025 | |
Master File (Detailed form) | 92D (4) | 3CEAA (Part B) | Part B is applicable if following conditions are satisfied:
|
30-Nov-2025 | INR 5,00,000 for non-furnishing of information and documentation |
Intimation by Designated Constituent Entity (DCE) – Master File Designation Form | 92D (4) | 3CEAB | Applicable to Indian entities meeting the above threshold and having more than one entity in India | 31-Oct-2025 |
TRANSFER PRICING COMPLIANCE TIMELINES
Compliance | Section under Indian Income-tax Act, 1961 | Form Number | Applicability | Due Date | Penalty for non-compliance |
---|---|---|---|---|---|
Intimation by DCE- CbC Notification (having HQ/ Alternate reporting entity outside India and filing the CbCR outside India) | 286 (1) | 3CEAC | The bilateral exchange relationship for the automatic exchange of CbC Reports between tax authorities of Parent Entity/Alternate Reporting Entity Jurisdiction and Indian jurisdiction is activated | Ten months from the end of reporting Accounting year of the HQ/ Alternate reporting entity (For Example, if the accounting year of the HQ/ Alternate reporting entity is 31 December 2024, then the due date for filing 3CEAC is 31 October 2025) | INR 5,00,000 – Furnishing of inaccurate information in CbCR INR5,000 / 15,000 / 50,000 per day for non-furnishing of CbCR – Depending on the days of delay of violation |
Country-by-Country Reporting (CbCR)- India HQ/Alternate reporting Entity | 286 (2) | 3CEAD | If Consolidated Group Revenue for preceding accounting year exceeds INR 6,400 Crores. | 12 months from the end of reporting Accounting year of the HQ/ Alternate reporting entity (For Example, if the accounting year of the Indian HQ/ Alternate reporting entity is 31 March 2025, then the due date for filing 3CEAD is 31 March 2026) | |
Safe Harbour Application for International Transactions | 92CB | 3CEFA | Applicable to only Indian entities. Various thresholds prescribed based on the activities of the Indian entity | 30-Nov-2025 | Not Applicable |
Safe Harbour Application for Specified Domestic Transactions | 92CB | 3CEFB | Applicable to only Indian entities. Various thresholds prescribed based on the activities of the Indian entity | 30-Nov-2025 | Not Applicable |
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