Chartered Accountants in India, working with clients across the UK

Domestic Transfer Pricing
Transfer Pricing · Domestic

Domestic transfer pricing,inside India.

Transfer pricing is not only about cross-border deals. Certain transactions between Indian related parties, called specified domestic transactions, must be at arm's length when they exceed ₹20 crore in a year, mainly where one party enjoys a tax holiday or a lower tax rate. We identify them, document them and include them in the report.

Threshold checkedFees agreed in writingIncluded in Form 48
CoversRelated Indian parties
Threshold₹20 crore a year
TriggerTax holidays and low rates
ReportForm 48

What is covered.

  • Tax holiday businessesTransactions of units claiming profit-linked deductions with related parties.
  • Lower-rate manufacturersNew manufacturing companies taxed at the concessional rate.
  • Transfers of goods or servicesBetween such units and other businesses of the same person.
  • ThresholdAggregate value above ₹20 crore in the year.
Old and new section numbers

From 1 April 2026 the Income-tax Act, 2025 has renumbered the transfer pricing provisions. Cases for years before tax year 2026-27 still run under the Income-tax Act, 1961, so this page uses the familiar section numbers. We apply whichever Act covers your year.

Why it matters.

The rules stop profit being shifted into a tax-free or low-tax unit. If prices are not at arm's length, the officer can reduce the deduction or increase the income. Documentation and penalties work as for international transactions.

How we help.

01
Identify

Related parties

And which transactions count.

02
Test

Threshold

Aggregate value for the year.

03
Price

Arm's length

Method and comparables.

04
Report

Form 48

And documentation.

Why UK companies choose us in India.

We speak UK and India

We work with your UK finance team, lawyers and auditors, and translate Indian requirements into plain English.

Reviewed before filing

Every filing and certificate is checked by a second Chartered Accountant before it goes in.

Fees agreed in writing

A written scope, timetable and fee before work starts.

A compliance calendar

One calendar of every MCA, RBI, GST and income-tax deadline for your Indian entity.

One team end to end

Set-up, accounts, payroll, tax, audit and RBI filings handled together.

Secure and fully online

Encrypted document sharing and digital signatures. Directors never need to travel.

Domestic TP for UK groups with several Indian entities.

We support UK groups headquartered anywhere in the UK with transfer pricing for their Indian subsidiaries and branches, working with their UK tax teams online.

London

City of LondonCanary WharfHarrowWembleySouthallHounslowIlfordEast HamCroydonEdgware

South East

ReadingSloughMilton KeynesOxfordWatfordLutonCrawleyGuildford

Midlands

BirminghamLeicesterCoventryNottinghamWolverhamptonDerbyNorthampton

North of England

ManchesterLeedsBradfordSheffieldLiverpoolNewcastlePreston

East and South West

CambridgePeterboroughBristolSwindonSouthamptonBath

Scotland, Wales, NI

EdinburghGlasgowAberdeenDundeeCardiffSwanseaBelfast

Domestic transfer pricing FAQs.

A listed transaction between related Indian parties, above ₹20 crore a year.
No. Mainly where a party has a tax holiday or a lower tax rate.
Yes. Specified domestic transactions are reported in Form 48.
Yes, similar to international transactions.

Several entities in India?

Tell us how they deal with each other. We will check the domestic rules.

This page is general guidance based on the Income-tax Act, 2025 and the rules and return forms as they stand. It is not legal or financial advice for your situation. Forms, eligibility and due dates can change each year, so please check with us before filing.