Documentation & Compliance
Master File, Local File, CbCR, contemporaneous documentation, safe harbours, the compliance calendar and audit defence.
Transfer Pricing Documentation: Master File, Local File & CbCR (2026)
The three-tier documentation architecture: what lives in the Master File, Local File and CbCR, the India thresholds that trigger each, and how to keep the three documents consistent.
Read docMaster File: Content, Triggers and Best Practices (Rule 10DA + OECD)
The Master File under India’s Rule 10DA and the OECD BEPS standard: the ₹1,000 cr trigger, the content blocks, the India–OECD deltas, and how to keep it consistent with the Local File and CbCR.
Read docRule 10D Documentation: The Complete Checklist
A Rule 10D documentation checklist for Indian transfer pricing — every item required, with practical tips for defending your Accept-Reject matrix before the TPO.
Read docCountry-by-Country Reporting (CbCR): Thresholds, Filing, Data Quality
CbCR under BEPS Action 13: the €750 mn / ₹1,000 cr thresholds, Form 3CEB and 3CEBA in India, the exchange of information, and the data quality risks that turn the CbCR into a scrutiny trigger.
Read docSafe Harbour Rules in India: Rule 10TD Guide
The Indian Safe Harbour Rules (Rule 10TA-10TE) — eligible international transactions, prescribed margins as amended to 2025, and how to elect via Form 3CEFA.
Read docContemporaneous Documentation: Deadlines and Penalty Protection
What "contemporaneous" means in Indian transfer pricing: the 30-day preparation window, the section 271AA penalty, the 282BC production mechanics, and the penalty protection that depends on the dates.
Read docIndia Transfer Pricing Compliance Calendar (2026): Every Deadline
Every India transfer-pricing deadline in one table: the return, Local File, Master File, CbCR, Form 3CEB, MAA and TPO windows — with the penalty exposure of missing each one.
Read docTP Audit Defense: TPO Proceedings, Scrutiny and Appeals
The Indian TP examination end to end: how the TPO proceeding runs, the adjustment theories, the AO interplay, the appeal route, and the documentation readiness that decides the outcome.
Read docTransfer Pricing Policy: Building a Defensible Company-Wide Framework
The company-wide TP policy: the components, the governance, the refresh triggers, the board reporting — and why the policy is the framework that makes every Local File consistent.
Read doc10 Documentation Weaknesses That Trigger Audits (and How to Fix Them)
The ten documentation weaknesses that open the transfer pricing file in examination — from the lost penalty shield to the silent matrix — each with the risk it carries and the remediation.
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Go from guide to finished study
Quartyl applies the method, PLI and screening steps above automatically — with documented reasons for every exclusion.