International Transaction Transfer Pricing
Every cross-border dealing between associated enterprises — goods, services, royalty, financing — must be priced at arm's length under Section 92B. We benchmark, document and defend all of it.
Direct Answer
An international transaction under Section 92B is any cross-border dealing between associated enterprises — goods, services, royalty/IP, or financing — that must be priced at arm's length once aggregate value exceeds ₹1 crore in a financial year.
What counts as an international transaction
Under Section 92B, an international transaction generally includes a transaction between two or more associated enterprises where either or both enterprises are non-residents and the arrangement affects profits, income, losses or assets. The definition extends beyond ordinary purchases and sales. It can cover services, financing, guarantees, royalty, cost allocation, restructuring, capital transactions and other cross-border arrangements.
The associated enterprise relationship is tested under Section 92A. Control may arise through shareholding, management, debt, dependence on intangibles, supply arrangements, board influence or other prescribed connections. A transaction can also be treated as deemed international where an associated enterprise influences the terms of a transaction with an unrelated party.
Our international transaction transfer pricing India services begin by identifying the complete transaction population, confirming the parties and legal arrangements, reconciling transaction values and determining which transfer pricing method best reflects the commercial substance.
We also review whether year-end adjustments, delayed receivables, guarantees, pass-through costs or group policy changes create additional reporting exposure. This early review helps align the pricing outcome with Form 3CEB, the Local File and the tax return before statutory deadlines.
Who this applies to
Indian subsidiaries of multinational groups, Indian multinationals with overseas operations, joint ventures, captive service centres and Indian businesses transacting with related non-resident entities.
Where aggregate international transactions exceed ₹1 crore, detailed Rule 10D documentation is generally required. Applicable transactions should also be reviewed for Form 3CEB reporting under Section 92E.
Every category of international transaction
We support the major transaction categories that commonly create Indian transfer pricing exposure.
Purchase & Sale of Goods
Imports and exports of finished goods, raw materials, components, spare parts and traded products. We review product comparability, market level, geography, volume, credit terms, freight, warranty and inventory risk before selecting CUP, resale price, cost plus or TNMM.
Intra-Group Services
Management fees, technical support, IT, finance, HR, marketing, procurement and shared services. We test whether services were actually received, whether they provide economic benefit, how costs were allocated and whether the mark-up is arm's length.
Royalty & IP
Brand, trademark, technology, software, know-how and licence arrangements. We examine ownership, DEMPE functions, contractual rights, expected benefits, comparable licence agreements and whether the Indian entity creates or enhances local marketing intangibles.
Intercompany Financing
Loans, guarantees, deposits, cash pooling, delayed receivables and other financial arrangements. Benchmarking considers currency, tenure, credit quality, security, subordination, market conditions and the borrower's realistic alternatives.
Other arrangements that may fall within Section 92B
Cost contribution arrangements, reimbursements, business restructurings, transfers of tangible or intangible property, issue or redemption of securities, receivables, guarantees and deemed international transactions can also require analysis. The accounting label does not determine the transfer pricing treatment; the actual conduct and economic effect matter.
How we approach every engagement
Our process connects transaction mapping, FAR analysis, benchmarking and statutory documentation so the final position remains consistent across agreements, accounts and filings.
Transaction Mapping
We review ledgers, agreements, invoices, financial statements and related-party records to identify and categorise all Section 92B transactions. Values are reconciled before the economic analysis begins.
Functional Analysis
We document functions, assets and risks for each party, identify the tested party and evaluate whether contractual terms match actual conduct. Unique intangibles and risk-control functions receive special attention.
Method Selection & Benchmarking
We evaluate CUP, resale price, cost plus, profit split, TNMM and other prescribed approaches, then perform a defensible comparable search or price analysis using the most appropriate method.
Documentation & Filing
We prepare the Local File or TP study, support intercompany policy alignment and coordinate Form 3CEB reporting. Conclusions are reconciled with agreements, invoices and financial statements.
Built for scrutiny, not just for filing
Defensible Benchmarking
Comparables, filters, adjustments and rejected-method analysis are documented clearly so the position can be explained during TPO proceedings.
Every Transaction Type
Goods, services, intangibles, financing, guarantees, reimbursements and restructuring are handled within one coordinated transfer pricing framework.
Litigation-Ready
Documentation is prepared with consistency, evidence and future assessment defence in mind—not merely to complete an annual filing.
Common questions
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Related: TP Documentation · Benchmarking & Comparability · Specified Domestic Transactions