The Central Board of Direct Taxes (CBDT) has issued revised transfer pricing documentation guidelines for FY 2025-26, significantly expanding the scope of required disclosures for multinational enterprises operating in India.
Master File & Local File Requirements
Entities with international transactions exceeding ₹50 crore must now maintain both a Master File (Form 3CEBA) and Local File (Form 3CEBB). The Master File threshold for Group revenue has been reduced to ₹500 crore.
Country-by-Country Reporting
CbCR obligations now apply to Indian constituent entities of foreign MNEs with consolidated group revenue above ₹5,500 crore. Secondary adjustment provisions have been clarified.
Safe Harbour Revisions
New safe harbour rates have been announced for IT-enabled services, software development, and contract R&D. The turnover threshold for safe harbour eligibility has been revised upward.
Documentation Deadline
Transfer pricing documentation must be prepared before the tax return filing date. Penalties for non-compliance range from 2% of the value of international transactions. Contact us now to ensure compliance.
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