What transfer pricing documentation is mandatory for an India subsidiary transacting with its foreign parent?

Any Indian entity with international transactions with an associated enterprise — goods, services, royalties, management fees, intercompany loans, and similar — must maintain transfer pricing documentation justifying that the pricing is at arm's length, and file an accountant's report in Form 3CEB certifying the same, due alongside the income tax return.

Beyond the basic documentation, two additional layers apply based on scale: a Master File, containing a group-level overview of the business, intangibles, and financial activities, is required once the Indian entity's consolidated group revenue and the value of international transactions cross prescribed thresholds. Country-by-Country Reporting, which discloses revenue, profit, and tax paid by jurisdiction for the whole multinational group, applies where the group's total consolidated revenue exceeds a much higher threshold (aligned with the OECD BEPS framework). Most mid-sized India subsidiaries will need Form 3CEB and standard documentation; Master File and CbCR generally apply only to larger multinational groups.