Indian Transfer Pricing Compliance for FY 2025-26: Local File, Master File, CbCR, Due Dates and Key Checkpointstransfer pricing complianceTransfer Pricing
A practical compliance guide for Indian MNEs and taxpayers entering the FY 2025-26 transfer pricing filing season
For businesses with cross-border related-party transactions, transfer pricing compliance is not merely a year-end filing exercise. The compliance framework can involve maintaining transfer pricing documentation, filing Form 3CEB, evaluating Master File requirements, and, for large multinational groups, meeting Country-by-Country Reporting (CbCR) obligations. The real compliance risk arises when these filings are prepared in isolation from the underlying agreements, financial statements, transaction ledgers, benchmarking and actual conduct.transfer pricing documentationForm 3CEB
For FY 2025-26, businesses should therefore start with a simple question: which transfer pricing compliances apply to us, what are the relevant thresholds and due dates, and is our underlying transfer pricing position ready to support the filings?
1. Local File and Form 3CEB: the starting point
A transfer pricing study under section 92D is required to be maintained where the aggregate value of international transactions exceeds INR 1 crore, or where specified domestic transactions (SDTs) exceed INR 20 crore in the circumstances covered by the transfer pricing provisions. The compliance material also identifies 31 October 2026 as the relevant due date for FY 2025-26 and notes a penalty exposure of 2% of the value of international transactions or SDTs for non-compliance.Section 92D
Form No. 3CEB, the accountant's report under section 92E, applies where international transactions are undertaken with foreign Associated Enterprises (AEs), irrespective of threshold. It can also apply to covered SDTs with Indian AEs where the prescribed conditions are met. For FY 2025-26, the indicated due date is 31 October 2026, with a stated penalty of INR 1,00,000 for failure to furnish the report.Section 92E
Practical point: Form 3CEB should not be treated as a transaction-listing exercise. Before sign-off, reconcile the related-party schedule, general ledger, agreements, invoices, foreign remittances and the TP study so that the nature and value of each reportable transaction are consistent.
| TP compliance | Applicability | Due date | Penalty for non-compliance |
|---|---|---|---|
| TP Study to be maintained u/s 92D | If aggregate value of international transactions > INR 1 crore
or If specified domestic transactions (SDT) > INR 20 crore in the circumstances covered by the transfer pricing provisions. |
31 October 2026 (1 month prior to ITR filing due date) |
2% of value of international transactions or SDT |
| Form No. 3CEB Report by an Accountant u/s 92E |
If international transactions (irrespective of threshold) are undertaken with foreign Associated Enterprises (AEs), or if covered SDTs are undertaken with Indian AEs where prescribed conditions are met. | 31 October 2026 (1 month prior to ITR filing due date) |
INR 1,00,000 |
2. Master File: Part A, Part B and Form 3CEAB
Master File compliance is separate from the entity-level Local File. Form No. 3CEAA Part A is applicable where international transactions are undertaken during the financial year and, as highlighted in the compliance material, applies to MNEs irrespective of the monetary threshold.
The detailed Master File in Form No. 3CEAA Part B applies where both threshold conditions are met: consolidated group revenue exceeds INR 500 crore and the aggregate value of international transactions exceeds INR 50 crore, or intangible-property-related international transactions exceed INR 10 crore. The indicated filing due date is 30 November 2026.
Where more than one constituent entity of the qualifying MNE group operates in India, Form No. 3CEAB is used for Master File intimation. The compliance material specifies 31 October 2026, being 30 days before the Master File filing due date.
Why this matters: The Master File tells the broader group story—business, global operations, intangibles, financing and transfer pricing policies. Indian entity-level documentation should therefore not contradict the group's Master File narrative.
| TP compliance | Applicability | Due date | Penalty for non-compliance |
|---|---|---|---|
| Form No. 3CEAA (Part A) Master File u/s 92D(4) — One Page Form |
Part A is applicable if international transactions are undertaken during the financial year. It applies to MNEs irrespective of the monetary threshold. | 30 November 2026 (Same as ITR filing due date) |
— |
| Form No. 3CEAA (Part B) Master File u/s 92D(4) — Detailed Form |
Part B is applicable if both conditions are satisfied: • Consolidated group revenue exceeds INR 500 crore and • Aggregate value of international transactions exceeds INR 50 crore or intangible-property-related international transactions exceed INR 10 crore. |
30 November 2026 | INR 5,00,000 — non-furnishing of information and documentation |
| Form No. 3CEAB Master File intimation u/s 92D(4) |
Applicable to MNEs crossing the Master File filing thresholds and having more than one entity operating in India. | 31 October 2026 (30 days prior to Master File filing due date) |
— |
3. Country-by-Country Reporting: know whether India has a filing or notification obligation
CbCR obligations are relevant to large multinational groups. The compliance material states that Form No. 3CEAD applies where consolidated group revenue for the preceding accounting year exceeds INR 6,400 crore. Where an activated bilateral automatic exchange relationship exists between India and the jurisdiction of the Parent Entity or Alternate Reporting Entity (ARE), the Indian constituent entity may not need to file the CbC Report in India and would instead generally have a notification obligation through Form No. 3CEAC.
For a group with an accounting year ending 31 December, the material identifies 31 December 2026 as the CbCR filing date, i.e., 12 months from the end of the group's accounting year. Form No. 3CEAC is indicated as due 10 months from the end of the group's accounting year—31 October 2026 for a 31 December year-end.
Compliance trap: Do not assume that because the parent entity files CbCR overseas, there is nothing to do in India. The Indian constituent entity should verify the reporting entity, jurisdiction, automatic exchange relationship and the resulting Indian notification/reporting obligation.
| TP compliance | Applicability | Due date | Penalty for non-compliance |
|---|---|---|---|
| Form No. 3CEAD CbC Report u/s 286(2)/(4) — Detailed Form |
If consolidated group revenue for the preceding accounting year exceeds INR 6,400 crore.
If an activated bilateral automatic exchange relationship exists between India and the jurisdiction of the Parent Entity or Alternate Reporting Entity (ARE), the Indian entity may not need to file CbCR in India and may instead have a notification obligation through Form No. 3CEAC. Reference: OECD CbCR exchange relationships |
For a group year ending 31 December: on or before 31 December 2026 (12 months from the end of the group’s accounting year). | INR 5,00,000 for furnishing inaccurate information in CbCR.
INR 5,000 / 15,000 / 50,000 per day for non-furnishing, depending on the delay. |
| Form No. 3CEAC CbCR Notification u/s 286(1) — One Page Form |
Filed when the Parent Entity/ARE files CbCR in its jurisdiction and an activated automatic exchange relationship exists between that jurisdiction and India. | 10 months from the end of the group’s accounting year i.e., 31 October 2026 for a 31 December year-end. |
— |
4. FY 2025-26 transfer pricing compliance calendar at a glance
| Compliance | Indicative due date | Key trigger / note |
|---|---|---|
| TP Study / Local File | 31 October 2026 | International transactions > INR 1 crore or covered SDTs > INR 20 crore |
| Form 3CEB | 31 October 2026 | International transactions with foreign AEs; covered SDTs as applicable |
| Form 3CEAB | 31 October 2026 | Qualifying Master File group with more than one entity in India |
| Form 3CEAA | 30 November 2026 | Part A / Part B depending on applicability and thresholds |
| Form 3CEAC | 10 months from group year-end | CbCR notification, where applicable |
| Form 3CEAD | 12 months from group year-end | CbC Report, where Indian filing obligation applies |
| Income-tax return for TP cases | 30 November 2026 | As stated in the FY 2025-26 compliance material |
5. Filing is only one part of TP compliance: year-end checkpoints
A technically correct form can still leave the taxpayer exposed if the underlying pricing and documentation do not align. Before closing the compliance cycle, businesses should review whether actual prices and margins follow the intercompany agreements and TP policy; whether true-up or true-down adjustments are required; and whether the consequences under GST, Customs, accounting standards and foreign exchange regulations have been considered.
The review should also cover overdue intercompany receivables and the applicable credit period, economic adjustments, segmental information, extraordinary items, foreign exchange differences, primary and secondary transactions, and the consistency of transaction characterisation across accounting records and statutory filings. Where Safe Harbour or an Advance Pricing Agreement applies, the agreed framework should be reflected in the year-end position.
For management fees, royalties and other intra-group service payments, contemporaneous need-benefit evidence is especially important. Emails, deliverables, cost allocation workings, benefit quantification, invoices and agreements should be collated while the evidence is readily available—not only after a TP assessment begins.
6. A practical pre-filing checklist
Map all international transactions and covered SDTs and reconcile them with the related-party disclosures and ledgers.
Check whether the actual transfer price or margin is within the agreed TP policy and the applicable arm's length benchmark.
Complete required true-up / true-down entries and assess secondary adjustment implications before finalisation, where relevant.
Review intercompany receivable and payable ageing against contractual credit periods.
Prepare reliable segmental workings for distinct business activities or internal comparables, where the TP method requires segmentation.
Ensure agreements reflect the actual functions, assets and risks (FAR) and renew or update intercompany agreements where necessary.
Collate supporting documentation for services, royalties, financing, guarantees, intangibles and business restructurings.
Check Local File, Form 3CEB, Master File and CbCR obligations independently—one filing does not automatically satisfy another.
7. Penalties make documentation quality a real financial issue
The compliance material highlights material penalty exposure: 2% of the value of international transactions or SDTs for specified TP documentation non-compliance; INR 1,00,000 in relation to Form 3CEB non-furnishing; INR 5,00,000 for non-furnishing of prescribed Master File information and documentation; and separate CbCR penalties, including consequences for inaccurate information and continuing delays.
The better approach is therefore to build the compliance file around audit defence from day one. The numbers in the return, Form 3CEB, financial statements, Local File and Master File should tell the same story.
Conclusion: prepare the TP position before preparing the forms
FY 2025-26 transfer pricing compliance should be approached as a connected process: identify transactions, test the pricing, complete year-end adjustments, reconcile financial information, establish documentation evidence and then file the applicable forms. This reduces last-minute inconsistencies and creates a much stronger defence if the case is selected for transfer pricing scrutiny.
For multinational groups, the immediate action is to confirm the applicability of the Local File / TP Study, Form 3CEB, Master File and CbCR requirements and build a compliance calendar around the relevant FY 2025-26 deadlines.
How SBC can assist
SBC supports businesses through the complete transfer pricing compliance lifecycle, including transaction mapping, benchmarking, Local File / TP Study, Form 3CEB review, Master File, CbCR, year-end TP health checks, TP adjustments and audit-defence readiness. The focus is not only on filing the required forms, but on ensuring that the underlying TP position is technically supportable and consistent across the business records.
Disclaimer: This article is intended for general informational purposes and is not a substitute for professional advice. Applicability should be evaluated based on the specific facts and legal provisions relevant to each taxpayer.
OECD India transfer pricing profile
Section 92C – Computation of arm’s length price
Section 92D – Maintenance of information and documents
Income Tax e-Filing – statutory forms
Income-tax Act, 1961 – official text
Income-tax Act, 2025 – transition resources
OECD Base Erosion and Profit Shifting project
Section 92BA – Specified domestic transactions
Section 92CA – Reference to Transfer Pricing Officer
Section 92CB – Safe harbour rules
Section 92CE – Secondary adjustment
Advance Pricing Agreement programme
Disclaimer: This article is intended for general informational purposes and is not a substitute for professional advice. Applicability should be evaluated based on the specific facts and legal provisions relevant to each taxpayer.