Chartered Accountants in India, working with clients across the UK

International Transfer Pricing
International Tax · Transfer pricing

Transfer pricing betweenyour UK and Indian entities.

Every charge between a UK parent and its Indian subsidiary or branch, whether for services, software, royalties, goods or loans, must be at an arm's length price. India expects detailed documentation and an annual accountant's report. We benchmark your transactions, prepare the documentation and certify the report on Form 48 (formerly 3CEB).

Benchmarking with Indian databasesFees agreed in writingAligned with UK group policy
RuleArm's length price
ReportForm 48, by a Chartered Accountant
Due31 October
RiskAdjustments and penalties

What transfer pricing covers.

Transfer pricing rules make sure profits are not shifted out of India through intercompany pricing. Any international transaction between associated enterprises, such as a UK parent and its Indian subsidiary or branch, must be priced as unrelated parties would price it.

The rules are in the Income-tax Act, 2025, which replaced the 1961 Act from 1 April 2026. See Transfer Pricing Laws for the legal background.

Common

Software and IT services

Indian subsidiaries providing development or support services to the UK group.

Common

Management and shared services

UK head office charges for HR, finance, IT and leadership.

Common

Royalties and brand fees

Payments for the use of UK intellectual property or trade marks.

Common

Loans and guarantees

Intercompany loans, interest rates and corporate guarantees.

Methods and benchmarking.

The arm's length price is set using one of the prescribed methods. For most Indian service subsidiaries, the transactional net margin method is used, comparing the subsidiary's profit margin with independent Indian companies doing similar work. See Benchmarking Analysis.

MethodOften used for
Transactional net margin methodCaptive IT, back-office and engineering service providers
Comparable uncontrolled priceInterest on loans, commodity sales
Cost plus methodContract manufacturing, simple services
Resale price methodDistributors buying from the UK group
Profit split methodHighly integrated operations with unique contributions

Documentation and annual reports.

RequirementWhoWhen
Accountant's reportAll entities with international transactionsForm 48 (was 3CEB) by 31 October
Local file documentationInternational transactions above ₹1 crore in the yearKept by the report date
Master fileLarger groups above the thresholdsForm 56 (was 3CEAA)
Country-by-country reportGroups with revenue above the CbCR thresholdUsually filed by the UK parent with HMRC
Income tax returnThe Indian entityBy 30 November in transfer pricing cases

See Transfer Pricing Documentation and Transfer Pricing Study.

Keeping India and the UK aligned.

HMRC applies its own transfer pricing rules to the UK side of the same transactions. A price that suits India but not the UK can lead to double taxation. We align the Indian documentation with your group policy and UK advisers, and where disputes arise, the India–UK tax treaty offers the mutual agreement procedure.

Safe harbour

For some services, India offers safe harbour margins that, if accepted, reduce disputes.

Advance pricing agreements

Unilateral or bilateral APAs with India and the UK can fix the method for several years.

Disputes

We handle assessments and appeals if an adjustment is made.

How we handle your transfer pricing.

01
Map

Identify every transaction

From the ledgers and intercompany agreements.

02
Analyse

Functions, assets and risks

Interviews with the Indian and UK teams.

03
Benchmark

Search for comparables

Using Indian databases and the right method.

04
Document

Prepare the local file

And review intercompany agreements and invoices.

05
Certify

Form 48 and the return

Our Chartered Accountant certifies the report by 31 October.

Risks of weak transfer pricing.

AdjustmentExtra income added

The officer can increase Indian taxable income to the arm's length level.

PenaltiesDocumentation and reporting

Separate penalties apply for missing documentation and late or missing reports.

Double taxNo matching UK relief

Without alignment, the same profit can be taxed in both countries.

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.

Transfer pricing for UK groups across the country.

We work with individuals and businesses in every part of the UK, coordinating the Indian side of their tax with their UK advisers 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

International transfer pricing FAQs.

Yes, if its international transactions with group companies exceed ₹1 crore in the year. Every entity with international transactions must also file the accountant's report, whatever the amount.
From tax year 2026-27, the transfer pricing accountant's report is filed on Form 48 under the Income-tax Rules, 2026.
By 31 October after the end of the tax year, with the income tax return due by 30 November.
Usually the transactional net margin method, comparing the subsidiary's cost-plus margin with independent Indian service companies.
Yes. An advance pricing agreement can fix the method and margin for future years, either with India alone or with both India and the UK.
The mutual agreement procedure under the India–UK treaty lets the two tax authorities resolve the double taxation.

Charging between your UK and Indian entities?

Tell us about your intercompany transactions. We will review the pricing and the documentation.

This page is general guidance based on Indian tax law, the India–UK tax treaty and related rules as they stand, including the Income-tax Act, 2025 that applies from 1 April 2026. We are Chartered Accountants in India; for UK tax returns we work alongside your UK accountant. This is not legal or financial advice for your situation, and rates and rules can change.