Rule 10TD - Safe Harbour

Safe harbour transfer pricing: declared prices accepted if they meet prescribed benchmarks and documentation requirements.

Safe harbour under Rule 10TD permits an eligible assessee's declared transfer price to be accepted if prescribed category-specific benchmarks for operating profit margins, interest rates for intra-group loans, or guarantee commissions are met; alternative benchmarks apply by transaction value, loan currency and credit rating, certain cost-pooling certifications are required for low value adding services, acceptance prevents comparability adjustments to the declared price, and transfer-pricing documentation and reporting obligations continue to apply.