Safe Harbour Rules Advisory

A simpler, lower-friction path to transfer pricing certainty — where eligible. We assess fit, model the impact, and file the election.

Overview

Pre-agreed margins in exchange for a minimum return

Safe Harbour Rules let eligible taxpayers accept a pre-agreed minimum margin or mark-up for specific transaction categories, in exchange for reduced scrutiny and dispute risk — a meaningful trade-off for the right business profile.

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Who this applies to

IT/ITES and KPO service providers, contract R&D centres, auto component manufacturers, and certain intra-group loan and guarantee arrangements.

What We Cover

Eligible categories under Rule 10TA-10TG

IT/ITES & KPO

Software development and knowledge process outsourcing services.

Contract R&D

Software and generic pharmaceutical R&D services.

Auto Components

Core and non-core auto component manufacturing and export.

Intra-Group Loans & Guarantees

Financing arrangements eligible for prescribed Safe Harbour margins.

Our Process

Model before you elect

Step 1

Eligibility Check

Confirm your transaction category and value fall within Safe Harbour scope.

Step 2

Margin Modelling

Compare Safe Harbour margins against your actual results and a standard TNMM position.

Step 3

Election Filing

File the election in Form 3CEFA within the prescribed timeline.

Step 4

Ongoing Monitoring

Reassess eligibility and benefit each year as your business evolves.

Why Work With Us

An honest cost-benefit view, not a one-size answer

Data-Driven Modelling

We quantify the actual margin trade-off before you elect.

Sector Expertise

Deep familiarity with IT/ITES, auto and financial Safe Harbour categories.

Annual Reassessment

We revisit the decision every year, not just once.

FAQs

Common questions

Is a Safe Harbour election reversible? +

Once validly exercised for the relevant years, an election is generally binding for that period, so the modelling step before electing is important.

Does Safe Harbour eliminate the need for TP documentation? +

No — Form 3CEB and supporting documentation are still required; Safe Harbour primarily reduces the scope for margin-related disputes.

Wondering if Safe Harbour makes sense for you?

Get a free eligibility and margin-impact review.