What is included in the fee for form 3ceb transfer pricing certification?
The Indian certification priced from the India desk, with the benchmarking built to Indian practice and reconciled to the group's other transfer-pricing files.
What would make form 3ceb transfer pricing certification cost more than the standard tier?
Whether the group's existing study can be relied on. Where it cannot, a local study is the work rather than the certificate.
Is the fee really fixed?
Yes, for the scope quoted. If the scope changes — another year appears, an entity turns up, a certificate becomes necessary — we re-quote before doing the work, so there is never an invoice you have not already agreed to.
Why does the Indian benchmarking need to be built in India?
Because the comparison has to be built the way it will be read. The analysis supporting a price is examined locally, against the databases, screening conventions and filters that local practice uses, and a search assembled elsewhere on different conventions tends to be argued about rather than accepted. That is not a statement about quality. It is about which evidence answers the question actually being asked. The description of the arrangement can and should be the group's own, written once. It is the comparability work underneath it that is built to Indian practice.
Will Indian comparables differ from the ones in our group study?
Usually, and that on its own is not a problem. Different markets produce different sets of companies, and a search run for another jurisdiction will have screened on criteria that do not fit the Indian entity. What cannot differ is the story: who performs which functions, who carries which risks, and which party is being tested. If the Indian set differs because the market differs, the files are consistent. If it differs because the two studies describe the business differently, that is the thing to fix before either of them is filed.
How do you keep our Indian and overseas transfer pricing files consistent?
By settling the functional analysis first and treating it as group property rather than as something each adviser writes locally. Once that is fixed, the local files draw on the same description of the arrangement, the same tested party and the same intercompany agreements, and vary only in the comparability work underneath. The reconciliation is then a check rather than a negotiation: transaction lists matched, figures traced to the same ledgers, periods aligned. Where a genuine difference survives, it is written down with its reason, because an unexplained difference is what invites the question.
Can you work alongside our existing group transfer pricing adviser?
Yes, and on group files that is the ordinary arrangement rather than an exception. The group adviser owns the overall policy and the master description. The India desk builds the local analysis and the certification that has to be filed there. What makes it work is agreeing at the start which document is authoritative on the functional analysis, and routing any change to it through one place. Two advisers each amending their own copy is how groups end up with two individually defensible files that contradict each other.
Our group study was written for another country, is it enough for India?
As a foundation, often. As the filed analysis, rarely. It will usually carry the description of the business, the intercompany agreements and the pricing policy, all of which travel. What it will not carry is a comparability analysis built on Indian data and local screening practice, and that is the part an officer examines first. The practical route is to keep the group document as the backbone, build the local analysis under it, and reconcile the two so that the numbers and the transaction list in each agree with the other.
Who is responsible if the Indian file and the group file disagree?
The group is, which is why the disagreement is worth finding before filing rather than afterwards. In practice the fix is procedural: one functional analysis, one transaction list, one set of intercompany agreements, and a named person who signs off changes to any of them. Where the Indian position genuinely has to differ, because the local requirement differs, the difference is recorded with its reason in both files. Silence about a difference is what turns a defensible position into an argument about credibility.
What is OECD Pillar Two?
A global minimum effective tax for large multinational groups, delivered through top-up taxes rather than a single global rate. Where a group's effective rate in a jurisdiction falls below the agreed minimum, the shortfall is collected — by the parent jurisdiction under the income inclusion rule, by the source jurisdiction under a domestic top-up, or as a backstop by other jurisdictions. Canada has enacted implementing legislation. The compliance burden is data, long before it is tax. See BEPS and Pillar Two.
What is the Liberalised Remittance Scheme?
The Reserve Bank of India framework under which a resident individual may remit up to an annual ceiling for permitted purposes — education, medical treatment, travel, maintenance of relatives, investment in shares or property abroad — with gifts and loans to non-residents inside the same ceiling. You declare the purpose to the bank on Form A2. The ceiling and the excluded purposes are set by the RBI and have changed more than once, so the figure to work from is the one current at the date of the transfer. See Form A2 and LRS remittances.
