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China to India · Transfer pricing

Transfer pricing between a Chinese 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 Chinese 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 China, so both files should tell one story.

What is specific to Chinese companies

Components and machinery from China are typical; transfer prices should match customs values.

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
Send a queryCorporate tax, GST and transfer pricing

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 Chinese rules change often; confirm the current position before acting. Chinese law points should be confirmed with a Chinese adviser.

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