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Australia to India · Transfer pricing

Transfer pricing between a Australian group and its Indian company

CA Utsav Dogra, Chartered Accountant, ICAI M. No. 542375 · Updated

In brief

Every transaction between the Indian company and a Australian group company must be at arm's length, benchmarked and reported in an accountant's report filed with the return by 30 November. The same transaction is tested in Australia, so both files should tell one story.

What is specific to Australian companies

The ATO tests the same transaction under Division 815; significant global entities have extra obligations.

Our services

How SU and Company helps

We price, document and defend intercompany transactions on the Indian side.

  • Functional analysis and benchmarking
  • Intercompany agreements review
  • Accountant's report and documentation
  • Year-end true-ups
  • Transfer pricing assessments

Questions

Can transfer pricing disputes be settled in advance?

Yes, through an advance pricing agreement with the Indian tax authorities, bilateral where the treaty partner participates.

General information as at 5 November 2026, not advice for a particular case. Indian and Australian rules change often; confirm the current position before acting. Australian law points should be confirmed with a Australian adviser.

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