Form 3CEB — TP accountant's report in India · competitively priced, fixed fee

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Form 3CEB — who files it, when it is due, what late filing costs, and what we charge to prepare it. India (Income Tax Department). Competitively priced Form 3CEB with a fixed fee agreed in writing before any work starts. Call the 24-hour helpline on +1 (416) 619-0068, or request a written quote today.

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  • 18,000+Clients served across our offices in India, the USA, Canada and the UAE
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  • 4Global offices — India, USA, Canada & UAE
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Send what you have. We price the engagement from your own documents, in writing, before any work starts.

24-hour helpline: +1 (416) 619-0068
  • Google rating 5.0 out of 5
  • 24-hour helpline: +1 (416) 619-0068
  • Offices in India, the USA, Canada and the UAE
In 60 words

Form 3CEB is an information return: The accountant's report on international and specified domestic transactions with associated enterprises. Indian entities with cross-border related-party transactions, including subsidiaries of Canadian and US groups.

Do you need this?

Indian entities with cross-border related-party transactions, including subsidiaries of Canadian and US groups.

Here is the part that decides your answer. The report is mandatory regardless of transaction size once there is an international related-party transaction, and it certifies method and pricing. It is the document an Indian transfer-pricing officer opens first.

The firm’s founder at his desk in the Delhi office

Transparent, fixed pricing for Form 3CEB India

A Form 3CEB fee is driven by the transactions, not the turnover: how many international related-party dealings there are, how many associated enterprises they run to, and whether each method and margin is already supported by a current study or has to be benchmarked before the report can be certified.

Transfer pricing — local file — fixed-fee price
From $2,500

in US dollars, fixed and quoted before work starts

The local file for one entity: functional analysis, method selection with the alternatives explained, comparables with the search documented, and the results tested against the range.
See the full fee page
Form 3CEB certification (India) — fixed-fee price
From $2,500

in US dollars, fixed and quoted before work starts

The accountant's report on international related-party transactions, with the prescribed documentation behind it and the method certified rather than asserted.
See the full fee page
Transfer pricing documentation
From $2,500

in US dollars, fixed and quoted before work starts

Local file, master file and benchmarking for groups trading across borders, documented to the standard the authority expects.
See the fee schedule
Corporate cross-border filing
From $999

in US dollars, fixed and quoted before work starts

Returns for companies with foreign subsidiaries, foreign income or foreign shareholders, and the schedules each of those triggers.
See the fee schedule
Foreign asset & information reporting
From $349

in US dollars, fixed and quoted before work starts

Disclosure of assets and interests held abroad, built once from a single asset list and filed on every side that asks for it.
See the fee schedule
Individual tax filing
From $349

in US dollars, fixed and quoted before work starts

One engagement for a personal return that touches more than one country: the income, the assets held abroad and the relief claimed against them.
See the fee schedule
Payroll & mobility setup
From $999

in US dollars, fixed and quoted before work starts

Payroll set up for a workforce split across countries, including the relief that stops the same salary being withheld on twice.
See the fee schedule
Non-resident & departure filings
From $349

in US dollars, fixed and quoted before work starts

The filings that follow a move: the departure year, the arrival year, and the income that keeps arriving from the country behind you.
See the fee schedule

All published fees on one page — the whole fee schedule in one place, with no from-to bands to decode.

What the reporting test actually looks at

What the test looks atWhere the figure comes from
The obligationThe accountant's report on international and specified domestic transactions with associated enterprises.
Who it bindsIndian entities with cross-border related-party transactions, including subsidiaries of Canadian and US groups.
Jurisdiction and authorityIndia — Income Tax Department
Category of filingInformation return

When it is due

Information returns are generally due with — or on the same timetable as — the return they accompany, so the deadline is the filing deadline of the underlying return unless the rules set a separate date. Where an extension covers the return, confirm whether it also covers this form; several information returns keep their own date. The deadline is set out in writing with the engagement, along with what has to be in our hands to meet it.

What late or missed filing costs

The penalty on an information return is charged per form and per year, and it does not depend on tax being owed. That is the whole risk profile: a filer with no tax to pay can still accumulate a substantial liability across unfiled years, and the exposure compounds with each additional entity or account that should have been reported. Relief exists for most of these situations, and it is conditional on how the correction is made. That is the part worth getting right.

The numbers, end to end

Worked through with figures, the mechanism looks like this.

Deduction on the price against tax on the gain

An NRI sells Indian property for ₹24,900,000 with an indexed cost of ₹13,695,000. Assume the buyer must deduct at 15% of the consideration, and assume tax on the gain at 12%.

ItemAmount
Sale consideration₹24,900,000
Cost taken into account₹13,695,000
Gain actually arising₹11,205,000
Deduction on the consideration (assumed 15%)₹3,735,000
Tax on the gain (assumed 12%)₹1,344,600
Cash held back beyond the real tax₹2,390,400

₹2,390,400 more is deducted than the transaction actually owes. A lower-deduction certificate obtained before closing is what releases it at the table; without one it sits with the department until a return recovers it. Change any one of those inputs and the answer moves, which is why we run it on your own figures rather than on an illustration.

Illustrative figures, not a client engagement: the amounts are chosen to make the mechanism legible, and the rates and thresholds are assumptions stated for the example only. We confirm every one of them against the issuing authority for your own tax year before anything is filed.

How we prepare and file it, and what it costs

The fee for Form 3CEB is fixed against a written scope and agreed before we start. It is not billed by the hour and it does not move after the fact. See the schedule fa — reporting foreign assets in an Indian return for comparable engagements.

From first call to filed

  1. 1We start with the chronology: dates, countries, and what has already been filed
  2. 2You get the scope and the fee in writing before we touch anything
  3. 3The work is prepared and reviewed by a named person, not a queue
  4. 4Nothing is filed until you have read it
  • Authorisation with each authority, so we see the assessments and slips directly rather than asking you for them.
  • 18,000+ clients served across 4 global offices: India, the USA, Canada and the UAE.
  • Consultations scheduled to your working day rather than ours.

One call is usually enough to know whether this is a filing or a project.

Read and approved for the 2025 and 2026 filing seasons by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants. Written as general guidance, not as a recommendation for your situation. Talk it through with us before acting on it.

Where ITR group comes into this file

People reach this page searching for ITR group. It is covered here as it applies to Form 3CEB — who it applies to, what has to be filed, and what it costs, at a fixed fee agreed before the work starts.

The report is mandatory regardless of transaction size once there is an international related-party transaction, and it certifies method and pricing.

From first contact to filed return

  1. Documents first, questions second

    We read the file before asking anything, so the questions we do ask are the ones that matter.

  2. A quote you can hold us to

    Fixed in writing against a defined scope. No hourly meter, and no revision after the fact.

  3. The order of filing decided deliberately

    Which return goes first can decide whether relief is available at all. That is planned, not discovered.

  4. Nothing filed without your sign-off

    You see the completed work, ask what you need to, and approve it before submission.

The difference a dedicated cross-border team makes

Factor Legal Quotient Hourly billing model
Pricing A fixed fee, agreed in writing before work starts Hourly, billed as incurred
Experience 15+ years of cross-border work, 18,000+ clients Varies by file
Both sides of the border Prepared together by one team, so relief is claimed exactly once One country at a time, reconciled later
Who reviews it A named practitioner, published on the page Whoever the queue reaches
Where the work happens Our offices in India, the USA, Canada and the UAE Whichever single office you can travel to

Key terms behind this page, defined

LRS
India's liberalised remittance scheme, permitting resident individuals to remit funds abroad within an annual limit for declared purposes.
Withholding certificate
An advance determination reducing withholding on a transaction to the tax actually expected — worth many times more applied for before closing than after.
Branch
A foreign operation that is the same legal person as the head office, so its results consolidate — at the cost of exposing the parent to the foreign system.
Form 15CB
A chartered accountant's certificate on the taxability and withholding of an Indian outward remittance, delivered under a banking deadline.
Form 3CEB India: Our analysis

The report is mandatory regardless of transaction size once there is an international related-party transaction, and it certifies method and pricing.

Whatever the file turns out to involve, the terms do not move: the scope and the fee are agreed in writing before any work starts, a named practitioner reviews the result, and nothing is filed until you have approved it.

The published fees closest to Form 3CEB India

Scope is the other variable. A single management-fee recharge brings the Form 3CEB obligation into play just as a full manufacturing arrangement does, so a narrow file stays narrow; specified domestic transactions, or a first year with no prior documentation to refresh, are what take it the other way.

Transfer pricing — local file
$2,500in US dollars, fixed before work starts

Covers: The local file for one entity: functional analysis, method selection with the alternatives explained, comparables with the search documented, and the results tested against the range.

What makes it bigger: The number of transaction types. Goods, services, royalties and financing are four analyses rather than one, and each needs its own method and its own comparables.

See this fee page
Form 3CEB certification (India)
$2,500in US dollars, fixed before work starts

Covers: The accountant's report on international related-party transactions, with the prescribed documentation behind it and the method certified rather than asserted.

What makes it bigger: Indian benchmarking practice. Comparables acceptable elsewhere in the group are not always acceptable to an Indian officer, so the study is often built locally.

See this fee page
TP benchmarking study
$2,500in US dollars, fixed before work starts

Covers: A documented search: screening criteria, quantitative and qualitative filters, a manual rejection log with reasons, and the resulting range with the tested party's position in it.

What makes it bigger: How defensible the comparables have to be. A study intended for a filing and a study intended to survive an audit are different pieces of work.

See this fee page

Why choose Legal Quotient for Form 3CEB India

18,000+ clients served

Individuals, expats and corporations across India, the USA, Canada and the UAE have filed with us — 15+ years of cross-border work.

You deal with the person who did the work

The practitioner who prepared and reviewed your file is the one who answers the question about it.

Residence is tested, not assumed

Where you are resident for treaty purposes is a question with a method. We work through it and write down the answer, with the facts it rests on.

Filed with the authority, not just prepared

The engagement runs to submission and to the correspondence that follows it, including the queries that arrive months later.

The team reviewing a file together at a desk
Two of the firm’s advisers at a desk in the Delhi office

From first document to filed return

  • Step 1: Start with a conversation about the facts – Dates, residence, where the income arose. Fifteen minutes is usually enough to know what applies.
  • Step 2: Scope and price, both written down – You get the scope and the fixed fee together, so there is no question later about what was included.
  • Step 3: Prepared by one team, reviewed by a named practitioner – The same people see both sides of the file, and the reviewer signs their name to it.
  • Step 4: Filed, then followed through – Submission is not the end of the engagement — the queries that arrive afterwards are part of it.

Quoted up front, in writing.

Contact Us 24-hour helpline +1 (416) 619-0068

The rest of this practice

Each of these carries its own guide, pricing pointers and FAQ.

Services these clients use most

Claiming DTAA relief — TRC, Form 10F and Form 67 together The full guide to claiming DTAA relief — trc, form 10f and form 67 together, with the fee fixed before any work starts.
IRS notice & CP letter response Its own page: IRS notice cp letter response — mechanism, deadlines and published fees.
Form NR301 — treaty benefit declaration Everything on nr301 treaty benefit declaration, at the same depth as this page.
Form 8938 vs FBAR — filing both Form 8938 vs FBAR filing both — the guide, the FAQ and the fixed fee.
Form 8802 — US residency certification The full guide to form 8802 US residency certification, with the fee fixed before any work starts.
Choosing a method — CUP Its own page: choosing a method — cup — mechanism, deadlines and published fees.
Form T1243 — deemed disposition Everything on T1243 deemed disposition, at the same depth as this page.
Payroll for a Canadian employee abroad Payroll for a Canadian employee abroad — the guide, the FAQ and the fixed fee.
Transfer pricing in India — s.92 and Form 3CEB The full guide to transfer pricing in India — s.92 and form 3ceb, with the fee fixed before any work starts.

Who we bring this work to

E-commerce & marketplaces cross-border tax The full guide to e-commerce & marketplaces cross border tax, with the fee fixed before any work starts.
Construction & contracting — relief you're probably missing Its own page: construction & contracting relief you're probably missing — mechanism, deadlines and published fees.
App & game studios cross-border tax Everything on app & game studios cross border tax, at the same depth as this page.
Tax for aid & NGO workers Aid & ngo workers tax — the guide, the FAQ and the fixed fee.
Architecture practices cross-border tax The full guide to architecture practices cross border tax, with the fee fixed before any work starts.
Family holding companies cross-border tax Its own page: family holding companies cross border tax — mechanism, deadlines and published fees.
Tax for Twitch & live streamers Everything on twitch & live streamers tax, at the same depth as this page.
Tax for adult-platform creators Adult-platform creators tax — the guide, the FAQ and the fixed fee.
Professors & lecturers — what we charge The full guide to professors & lecturers what we charge, with the fee fixed before any work starts.

The corridors we work every week

Canada–Netherlands tax corridor The full guide to Canada Netherlands tax, with the fee fixed before any work starts.
United States tax for expats — country guide Its own page: United States tax for expats — mechanism, deadlines and published fees.
United Kingdom tax for expats — country guide Everything on United Kingdom tax for expats, at the same depth as this page.
Uruguay tax for expats — country guide Uruguay tax for expats — the guide, the FAQ and the fixed fee.
Hungary tax for expats — country guide The full guide to hungary tax for expats, with the fee fixed before any work starts.
Georgia tax for expats — country guide Its own page: georgia tax for expats — mechanism, deadlines and published fees.
Trinidad & Tobago tax for expats — country guide Everything on Trinidad & tobago tax for expats, at the same depth as this page.
Bahrain tax for expats — country guide Bahrain tax for expats — the guide, the FAQ and the fixed fee.
Pakistan tax for expats — country guide The full guide to Pakistan tax for expats, with the fee fixed before any work starts.

The people on your file

Named practitioners, each with the countries and the part of a cross-border file they carry, across India, the USA, Canada and the UAE. Every page on this site says who reviewed it, and the reviewer is one of these people rather than an unnamed team.

Udit Gupta, International tax, cross-border tax and transfer pricing: USA, Canada, India and UAE, Legal Quotient Consultants
Udit Gupta
Director, International tax, cross-border tax and transfer pricing: USA, Canada, India and UAE

CA (India), CA (Malaysia)

Reviews and signs off the practice's cross-border positions, and carries final responsibility for the treaty analysis on every file that leaves any of our offices.

Udit Gupta on LinkedIn

Anmol Mittal, USA and Canada international tax, cross-border tax and transfer pricing, Legal Quotient Consultants
Anmol Mittal
Director, USA and Canada international tax, cross-border tax and transfer pricing

CPA (Canada), CPA (USA), CA (India)

Files that have to be right on both sides of the US–Canada border at once — dual filings, streamlined catch-ups, and the foreign tax credit reconciliation between them.

Anmol Mittal on LinkedIn

Vinayak Indolia, CFO services for Canada and India, Legal Quotient Consultants
Vinayak Indolia
Director, CFO services for Canada and India

CPA (Canada), CA (India)

CFO services for businesses in Canada and India: the tax position and the finance function made to agree, structure reviews, intercompany policy, and the reporting a board can act on.

Vinayak Indolia on LinkedIn

Meet the whole team

What these engagements turn on

Case study 1

First Form 3CEB prepared for a newly established Indian subsidiary

A Canadian group's newly incorporated Indian subsidiary had begun invoicing its parent for services within its first year and had not realised the reporting obligation attached from the first transaction, regardless of the modest amounts involved. We identified the international transactions requiring disclosure, arranged the benchmarking analysis to support the pricing, and had the accountant's report prepared and filed alongside the return. The subsidiary's first year of related-party dealings was properly documented from the outset.

Case study 2

Pricing method revisited after an assessment questioned the benchmarking

An Indian entity's Form 3CEB had certified a transfer-pricing method that an assessing officer later challenged as inappropriate for the nature of the transaction. We reviewed the underlying benchmarking study, considered whether an alternative method better fit the facts, and prepared a revised analysis supporting the position in the assessment proceedings. The engagement produced a defensible submission built on a method the facts actually supported.

Case study 3

Specified domestic transaction identified and added to an existing filing

A group had been filing Form 3CEB for its international transactions for years without recognising that a domestic arrangement with a related Indian entity also met the conditions for a specified domestic transaction. We reviewed the arrangement against the applicable conditions, confirmed it was in scope, and ensured the current year's filing captured it alongside the existing international disclosures. The correction closed a gap the client had not been aware of.

Case study 4

Transfer-pricing report reconciled against the tax audit before filing

A subsidiary's transfer-pricing accountant's report and its separate tax-audit report were being prepared by two teams working somewhat independently, with a risk the related-party figures in each would not match. We coordinated the two workstreams, reconciled the intercompany figures against a single source, and confirmed both filings told a consistent story before either was submitted. The engagement removed an obvious point of internal inconsistency an assessing officer could otherwise have raised.

Case study 5

An Indian Company Paying a Foreign Supplier

Payments abroad carry deduction at source and a certification filed before the money moves. Whether the treaty reduces the rate depends on what is being bought, and the classification is the decision the whole filing rests on.

Read how this one runs
Case study 6

A Distribution From a Trust Set Up Abroad

A distribution can be capital in the trust's country and income here, and the reporting attaches to the beneficiary rather than the trustee. The work is characterising the payment before it is received where possible.

Read how this one runs
Case study 7

Whether the Year Made Someone an NRI

Indian residence is decided by presence tests applied to the financial year, and a single trip can change the answer for the whole of it. The status is established before any return or exemption is considered.

Read how this one runs
Case study 8

Deduction at Source on Deposit Interest, Recovered

Where the treaty rate is lower than what was deducted, the difference comes back through a return rather than at source. The file establishes entitlement and files for the years still open.

Read how this one runs

All case studies — every published engagement in one place.

Where we deliver this work

Each of these carries its own guide, pricing pointers and FAQ.

Where the work is delivered
More coverage detail

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

Strategy and compliance for income, assets and families spread across borders.

Treaty residency & tie-breaker
FATCA reporting (Form 8938)
Foreign tax credit (Form 1116)
Multi-country filing calendar
Real estate holding structures
International tax planning
Pre-immigration tax planning
Family office structures
One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.
U.S. & Cross-Border Tax Returns
Form 1040 from abroad
US state non-resident returns
FBAR (FinCEN 114) filing
Form 5472 — foreign-owned US corp
FIRPTA withholding (Form 8288)
US estate tax exposure
IRS streamlined foreign offshore
PFIC reporting (Form 8621)
Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.
Expat & Emigration Tax
Departure tax leaving Canada
T1161 properties on emigration
Residency planning
Step-up in cost base on arrival
Split-year residency
Employment income under a treaty
Social security totalization
Returning to Canada after years abroad
The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.
Non-Resident Canadian Tax
Section 216 rental return
NR4 & NR6 withholding
Section 217 pension return
Section 116 clearance certificate
Regulation 105 waiver
Non-resident employment income
Taxable Canadian property
Part XIII withholding review
Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.
Transfer Pricing & BEPS
s.247 contemporaneous documentation
Functional & risk analysis
Benchmarking study
Intercompany agreements
Country-by-country report
BEPS & Pillar Two
Permanent establishment risk
TP audit defence file
Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.
Cross-Border Estates & Trusts
Cross-border wills
US estate tax for non-resident aliens
Terminal return & clearance certificate
Non-resident trusts (s.94)
T1141 & T1142 trust reporting
Inheriting property abroad
Graduated rate estates
Post-mortem planning & pipeline
Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.
Cross-Border Corporate Tax
Entity selection across borders
Business profits & PE
Intercompany loans & thin cap
Paying dividends to a foreign parent
Global mobility & day tracking
Debt vs equity funding
Branch or subsidiary
Cross-border M&A due diligence
Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.
India Tax for NRIs & Returning Residents
NRI residency day tests
NRE, NRO & FCNR accounts
TDS on property (s.195)
Lower or nil TDS certificate
Repatriating sale proceeds
Capital gains on Indian shares
India–Canada DTAA
ITR-2 for NRIs
The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.
Canadian Tax with a Foreign Element
T1135 foreign property
T1134 foreign affiliates
Departure tax
Newcomer's first return
Returning to Canada
Split-year residency
US citizens in Canada
Canada–US corridor
Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.
UAE Tax for Expats & Their Home Country
Expat tax in the UAE
Moving to the UAE
Moving back from the UAE
UAE property purchases
Retiring in the UAE
Canada–UAE corridor
India–UAE DTAA
US–UAE corridor
A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

Industries & Client Types We Serve Worldwide

Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies
Global E-commerce & Marketplaces
  • Foreign VAT / GST / sales tax registrations
  • Marketplace withholding reviews
  • Inventory nexus & PE analysis
  • Multi-currency books reconciled
Explore E-commerce & Marketplaces
Technology & SaaS
  • Cross-border revenue sourcing & withholding
  • IP structuring with real substance
  • Equity for cross-border teams
  • U.S. expansion: entity & PE setup
Explore Technology & SaaS
Cross-Border Real Estate

Foreign property income and sales are taxed in both countries by default; Section 216, FIRPTA and treaty credits are the standing toolkit.

Property is taxed where it sits, which is the one rule no treaty overrides. What the treaty does decide is the credit, the rate on the rent and what happens on the sale — and the clearance certificate on a disposition is applied for before closing, not after the buyer has already held the money back.

  • Section 216 rental returns
  • FIRPTA withholding recovery
  • Section 116 clearance
  • Treaty credit optimization
Explore Real Estate
Importers, Exporters & Manufacturers
  • Transfer pricing documentation (s.247)
  • Customs value vs transfer price
  • Foreign affiliate reporting (T1134)
  • Country-by-country reporting
Explore Trade & Manufacturing
Athletes, Artists & Entertainers
  • Reg 105 & U.S. CWA agreements
  • Multi-state & country calendars
  • Touring income allocation
  • Royalty & image-rights withholding
Explore Athletes & Entertainers
Remote Workers & Digital Nomads
  • Residency analysis before moving
  • Employer payroll exposure
  • Totalization & social security
  • Foreign tax credits
Explore Remote Workers
Investment Funds & Holding Companies
  • Treaty access & PPT reviews
  • FAPI & surplus computations
  • Withholding-efficient routing
  • Governance & substance
Explore Funds & Holdcos

Form 3CEB — questions we are asked

Do I file Form 3CEB even if no tax is owed?

Information return obligations of this kind are generally required on the facts rather than on the tax result, so a nil position does not remove one. Indian entities with cross-border related-party transactions, including subsidiaries of Canadian and US groups.

What happens if I have missed Form 3CEB for several years?

Missed years are dealt with as a package rather than one at a time, because the route chosen for the first year affects the relief available for the rest. We map the years and the obligations before anything is filed.

Is Form 3CEB the same as the other reports I already file?

No. The accountant's report on international and specified domestic transactions with associated enterprises. Satisfying a different obligation, even one covering the same accounts or entity, does nothing for this one.

Is Form 3CEB required regardless of how small the related-party transaction is?

Yes — once there is an international transaction with an associated enterprise, the reporting requirement applies regardless of the transaction's size. There is no minimum threshold below which the obligation disappears, which surprises businesses used to thresholds elsewhere in the tax system.

What does the accountant actually certify in Form 3CEB?

The accountant certifies the international and specified domestic transactions entered into with associated enterprises, the method used to price them, and that the pricing follows the arm's length standard the transfer-pricing rules require. It is this certification an assessing officer or transfer-pricing officer reviews first when examining a related-party position.

How does Form 3CEB relate to the underlying benchmarking study?

The report certifies the pricing position, and the benchmarking study is usually the evidence that supports it — the analysis showing comparable transactions between unrelated parties and how the tested transaction's pricing measures against them. A report filed without a benchmarking study behind it is a certification with nothing substantive to stand on if it is questioned.

Does Form 3CEB cover domestic related-party transactions as well as cross-border ones?

It covers specified domestic transactions in addition to international ones, though the domestic category applies more narrowly and depends on specific conditions being met. Most subsidiaries of foreign groups are drawn into this form through their international transactions with the parent or fellow subsidiaries rather than through domestic dealings.

What is OECD Pillar One?

The part of the international agreement that reallocates a share of taxing rights over the very largest and most profitable groups to the jurisdictions where their customers and users are, regardless of physical presence — plus a simplified approach to routine marketing and distribution returns. It is aimed at the digitalised economy problem that physical-presence rules could not reach, and its implementation is still moving, which is why we read the current instrument rather than the original blueprint. See BEPS and Pillar Two.

What is DTAA?

DTAA — a Double Taxation Avoidance Agreement — is India's term for a tax treaty. It allocates taxing rights between India and the other country, caps withholding on cross-border payments, and gives relief for income taxed twice by either exempting it or crediting the foreign tax. Relief is claimed, and from the Indian side that normally means a tax residency certificate, Form 10F and Form 67. See DTAA relief.

Tax terms explained
MLIBranchFC-TRSTrailing liabilityBeneficial ownershipGift splittingCloser connectionAlter ego trustReasonable causeSection 195 TDSControlled foreign affiliateDouble taxationAngel taxEconomic double taxation Browse the full A–Z glossary

Forms and situations related to Form 3CEB

Nearby pages

All Indian formsForm A2 — LRS remittance (India)Form 15G / 15H — no-deduction declarations (India)Form 26AS — tax credit statement (India)Form 24Q — TDS on salary (India)Form 3CEAC — CbCR intimation (India)Schedule TR — tax relief claimed (India)

Where this leads next

DTAA relief — India and the United StatesLeaving India — becoming an NRIIndian pension received abroadSafe harbour rules for Indian TPTransfer pricing in India — s.92 and Form 3CEBLiaison office reporting and closure

Answered questions

Who files Form 3CEB?What is the late filing penalty for Form 3CEB?
A named reviewer on every filing

Form 3CEB, quoted before we start

One call to the 24-hour helpline is enough to tell you what has to be filed, what it costs, and whether you need us at all.

Contact Us 24-hour helpline +1 (416) 619-0068 See fixed fees
  • Fixed fees agreed before work starts
  • 24-hour helpline, +1 (416) 619-0068
  • A named reviewer signs off every filing

Our practitioners are alumni of leading accounting and tax institutions

Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.

Request a Quote +1 (416) 619-0068