Specified Domestic Transactions

Even purely domestic related-party dealings can trigger transfer pricing compliance in India. We identify exposure and document it correctly.

Overview

What is a Specified Domestic Transaction (SDT)?

Under Section 92BA, certain domestic related-party transactions — such as payments to entities claiming profit-linked tax deductions (e.g. under Section 80-IA), transactions between a company and its related domestic parties, and other prescribed categories — are subject to transfer pricing rules where the aggregate value exceeds ₹20 crore in a financial year.

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Who this applies to

Indian companies with material related-party transactions inside India, particularly groups with entities enjoying tax holidays or profit-linked deductions.

What We Cover

Common SDT categories

Tax-Holiday Entity Transactions

Transactions with related units claiming Section 80-IA or similar profit-linked deductions.

Intra-Group Domestic Pricing

Goods, services and cost allocations between related domestic group companies.

Domestic Financing

Intercompany loans and guarantees between related Indian entities.

Domestic Royalty & IP

Licensing arrangements between related Indian companies.

Our Process

How we approach every SDT engagement

Step 1

Threshold Testing

Identify whether aggregate domestic related-party transactions cross the ₹20 crore threshold.

Step 2

Transaction Categorisation

Map each transaction against the specific SDT categories under Section 92BA.

Step 3

Benchmarking

Apply the appropriate method using domestic comparable data.

Step 4

Documentation & 3CEB

Prepare and file SDT-specific documentation and reporting.

Why Work With Us

SDT exposure is easy to miss — we don't miss it

Threshold Vigilance

We track SDT thresholds as your group structure evolves.

Domestic Comparables

Access to Indian financial databases for defensible benchmarking.

Integrated Filing

SDT documentation prepared alongside your international TP filings.

FAQs

Common questions

Does SDT apply if I have no cross-border transactions? +

Yes. SDT rules apply purely to domestic related-party transactions and are entirely independent of any cross-border dealings.

Is Form 3CEB required for SDTs? +

Yes — Specified Domestic Transactions must also be reported in Form 3CEB alongside international transactions, once the ₹20 crore threshold is crossed.

Not sure if SDT rules apply to you?

We'll assess your domestic related-party exposure, free.