Transfer pricing

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Querist : Anonymous

Querist : Anonymous (Querist)

20 January 2015 When transfer pricing documentation need to be prepared?

Amol S Joglekar

Amol S Joglekar (Expert)
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20 January 2015 now a days there are 2 types...
01. International Transfer Pricing and
02. Domestic Transfer Pricing.

The documentation is accordingly required to be maintained as and when the provisions of any of these 2 are hit.

Querist : Anonymous

Querist : Anonymous (Querist)

20 January 2015 in case of international transaction, when documentation need to be prepared (at year end or beginning) in case transactions are made on various dates in previous year and current year

Aashok Kumar Sharma online

Aashok Kumar Sharma online

(Expert)
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02 August 2025 In case of **international transactions**, transfer pricing documentation requirements are governed by **Rule 10D of the Indian Income Tax Rules** (assuming you're referring to Indian law, based on context).

### 📌 **When should transfer pricing documentation be prepared?**

According to Indian tax laws:

> **Transfer pricing documentation must be maintained contemporaneously — meaning it should be ready by the due date for filing the income tax return for the relevant financial year.**

### ✅ Key Points:

1. **Documentation Due Date:**

* Documentation should be prepared **before the due date of filing the income tax return** (usually **31st October** following the financial year).
* So, for **FY 2024–25**, documentation must be ready **by 31 October 2025** (unless extended).

2. **Multiple Transactions Over the Year:**

* If international transactions are made **on various dates during the year**, documentation must cover **all such transactions** throughout the financial year.
* Even if the transaction dates span both the **previous year (PY)** and **current year (CY)**, documentation for a particular PY should include all international transactions that occurred **during that year** (1 April to 31 March).

3. **"Beginning or End of Year" Clarification:**

* **Not at the beginning** of the year — because actual transactions may evolve.
* **Not strictly at the end** — rather, by the **return filing date**, ensuring full-year coverage.
* Best practice: Maintain records throughout the year and compile formal documentation **soon after the financial year ends**.

4. **Master File and CbCR (for MNEs):**

* If applicable, Master File and Country-by-Country Reporting (CbCR) requirements must also be met with specific forms and deadlines (Form 3CEAA, 3CEAB, 3CEAC, etc.).

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Would you like a template or checklist for what needs to go into the documentation under Rule 10D?

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