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Foreign Companies & NRIs · From Japan

Transfer Pricing Compliance in India for Companies from Japan

Arm's-length pricing for dealings with your group companies — transfer pricing study, documentation and Form 3CEB.

  • Identification of associated enterprises and international transactions for the year
  • Functional, asset and risk (FAR) analysis of the Indian entity
  • Selection of the most appropriate method and benchmarking against comparable companies
  • Transfer pricing study report and local documentation as prescribed
Form 3CEB filed before the due date (31 October under current rules, unless extended) Track every step online Secure document vault No travel to India needed Calls in your time zone

About Transfer Pricing Compliance in India

Indian tax law requires that transactions between an Indian company and its foreign parent or other associated enterprises, such as management fees, royalties, loans, sales of goods or provision of services, be priced as they would be between independent parties. The Indian entity must report every such international transaction in Form 3CEB, certified by a chartered accountant, and keep a transfer pricing study that justifies the pricing with comparable data when the aggregate value crosses the prescribed threshold. Fastlegal prepares the benchmarking study, the documentation and the Form 3CEB filing, and supports you if the tax office questions the pricing. For companies and individuals in Japan, Fastlegal runs the entire process remotely: your documents are apostilled in Japan, we prepare and file everything with the Indian authorities, and you track each step — and pay — from your dashboard in Tokyo hours.

From Japan to India: what to know

  • India and Japan have a double-taxation avoidance agreement (DTAA) in force. Dividends, royalties, fees and interest paid to the Japanese parent may qualify for treaty rates on production of a tax residency certificate and Form 10F — we confirm the applicable rate for your structure.
  • Our working hours (10am–7pm IST) are roughly 1:30 pm–10:30 pm in Tokyo. We schedule calls inside that overlap or at a time that suits you.
  • Fees are invoiced in INR and can be paid by JPY card (your bank converts) or by wire transfer to our Indian bank account.

What's included

  • Identification of associated enterprises and international transactions for the year
  • Functional, asset and risk (FAR) analysis of the Indian entity
  • Selection of the most appropriate method and benchmarking against comparable companies
  • Transfer pricing study report and local documentation as prescribed
  • Preparation and filing of Form 3CEB with the accountant's certification
  • Master file (Form 3CEAA) and related intimation (Form 3CEAB), where thresholds apply
  • Guidance on intra-group agreements and pricing policies for the following year

Documents required

  • Audited or provisional financial statements of the Indian entity
  • Group structure chart showing all associated enterprises
  • Intra-group agreements: services, royalty, licence, loan, distribution or cost-sharing
  • Ledger of all transactions with group companies, with invoices and amounts in both currencies
  • Description of the functions performed, assets used and risks borne by the Indian entity
  • Group transfer pricing policy or master file, if one exists
  • Prior-year Form 3CEB and transfer pricing study, if any
Transparent pricing

One fixed professional fee, inclusive of GST, agreed with you before any work starts — no hourly billing, no surprises, and nothing charged until you approve it. Database subscription or benchmarking data charges, if any, and penalties for non-compliance payable at actuals.

How it works

1

Order & pay online

Subscribe to annual transfer pricing compliance and pay online in INR or by international card; we scope your related-party transactions on a call.

2

Upload documents in your dashboard

Upload financials, group agreements and the related-party ledger to your Fastlegal dashboard.

3

We benchmark, document and file Form 3CEB

We perform the FAR analysis, run the benchmarking, prepare the study report and documentation, and file Form 3CEB certified by a chartered accountant.

4

Track & download

Track progress in your dashboard and download the study report, documentation and the filed Form 3CEB acknowledgement.

Get Transfer Pricing Compliance in India done — fully online

Documents apostilled or notarised in your country • We liaise with RBI, MCA and GST authorities • Track everything from your dashboard

Frequently Asked Questions

Do I need to come to India for Transfer Pricing?↓

No. Everything is done remotely for clients in Japan. Signatures are handled with digital signature certificates and apostilled documents; we represent you before the Indian authorities.

How are my Japan documents legalised for India?↓

Japan is party to the Hague Apostille Convention, so each document is notarised and then apostilled by the competent authority in Japan. India accepts apostilled documents without further embassy attestation. We send you a checklist of exactly which documents need this.

Can I pay from Japan?↓

Yes. You pay in INR by international card (JPY is converted by your bank) or by wire transfer; the GST invoice appears in your dashboard immediately.

When can we talk?↓

Our team works 10am–7pm IST, which is about 1:30 pm–10:30 pm in Tokyo. Book a call inside that window or tell us a time that suits you.

Who needs to file Form 3CEB?↓

Any Indian taxpayer that has entered into an international transaction with an associated enterprise during the year, regardless of amount, must file Form 3CEB. Certain specified domestic transactions above the prescribed value are also covered.

When is transfer pricing documentation mandatory?↓

A detailed transfer pricing study is mandatory once the aggregate value of international transactions in the year exceeds the prescribed threshold under current rules. Below it, the entity must still be able to show that pricing is at arm's length, so we recommend at least a basic analysis.

What is the due date?↓

Form 3CEB is due by 31 October following the financial year under current rules, unless the government extends it, and the income tax return of a company with transfer pricing obligations is due by 30 November. We plan the benchmarking well ahead so the audit and tax return are not held up.

What are the consequences of non-compliance?↓

Penalties apply for failing to file Form 3CEB, for not maintaining documentation and for not furnishing it when asked, and the tax officer may adjust the taxable income if pricing is found not to be at arm's length. Proper documentation is the main defence.

Can this be done without anyone visiting India?↓

Yes. The analysis is based on financial data, agreements and descriptions of your operations shared through the dashboard, and the form is filed digitally by the certifying chartered accountant.

One dashboard for all your compliance

Add your companies, LLPs and firms, keep documents in one vault, and never miss a due date.

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Transfer Pricing Compliance in India

Form 3CEB filed before the due date (31 October under current rules, unless extended)