Practice Brief • Income Tax & Direct Taxation
Transfer Pricing (3CEB) & Cross-Border Tax
Arm's length structuring, Form 3CEB certification, TP study, and DTAA treaty relief.
Turnaround: 2 to 3 weeks for full TP study; 24-48 hours for Form 15CA/15CB
Practice Lead: CA. R.A. Dhoot & Direct Tax Practice Team
Practice Methodology & Regulatory Scope
With cross-border transactions under aggressive scrutiny, our International Tax Practice delivers robust transfer pricing documentation, inter-company agreements, and APA advisory, safeguarding clients against transfer pricing adjustments and penalties.
Governing Statutory Acts & Guidelines
Sections 92 to 92F of Income Tax Act 1961
Form 3CEB & Rule 10D
OECD Transfer Pricing Guidelines 2022
Tangible Client Deliverables
1
Form 3CEB Certification by Chartered Accountant2
Transfer Pricing Local File with benchmarking studies using Capitalline & Prowess3
Master File (Form 3CEAA) and Country-by-Country Reporting (CbCR - Form 3CEAD)4
DTAA Withholding Tax Opinions & Form 15CA / 15CB Certifications5
Equalisation Levy & Significant Economic Presence (SEP) AuditMeasurable Enterprise Safeguards
Substantiated arm's length margins preventing high-quantum secondary adjustments
Protection against 200% misreporting penalties under Section 270A
Smooth repatriation of royalty, FTS, and management fees across borders
Statutory Practice FAQs
Q: When is Transfer Pricing documentation (Form 3CEB) mandatory in India?
A: Form 3CEB is mandatory for any enterprise that has entered into an international transaction or Specified Domestic Transaction (SDT) exceeding ₹20 Crores with Associated Enterprises during the relevant financial year.
Partner Consultation
Engage Practice Partner
Schedule an in-person chambers discussion or encrypted virtual conference with our senior practice leader.
Designated Partner Lead:
CA. R.A. Dhoot & Direct Tax Practice Team
ICAI Fellow Chartered Accountant
Strict client confidentiality maintained under ICAI Code of Ethics.