Chartered Accountants◆Practising since 2016

Hong Kong to India · Transfer pricing

Transfer pricing between a Hong Kong 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 Hong Kong 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 Hong Kong, so both files should tell one story.

What is specific to Hong Kong companies

Hong Kong trading hubs are the usual counterparty; the transfer price of goods should match the Indian customs value.

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

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