Why domestic TP is easy to overlook

Transfer pricing is often associated primarily with cross-border transactions, but specified domestic transactions between related parties above the prescribed threshold also fall within transfer pricing documentation and reporting requirements — a category businesses sometimes miss entirely, assuming TP is purely an international-tax concern.

Transactions that commonly trigger domestic TP obligations

Why this catches businesses off guard

A business may correctly conclude it has no international-tax exposure requiring Form 3CEB, and stop the analysis there — without separately checking whether any of its domestic transactions meet the related-party and threshold criteria that independently trigger domestic TP compliance.

What to do about it

A practical starting point

As part of your annual tax compliance review, explicitly ask whether any domestic related-party transactions exist and meet the threshold — don't rely on the international-transaction analysis alone to capture this separate, easily-missed obligation.

This article provides general guidance for educational purposes and reflects our understanding of the law as of the publication date. It is not a substitute for professional advice tailored to your specific facts. Tax and regulatory provisions change, and thresholds/deadlines should always be verified at the time of action. Please speak with our team before relying on this for a specific decision.
Need help with this directly? See our International Taxation Services →
CR
CA Rajesh Bhagat
International Tax Partner · VRKSJP & Co

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