Section 171
Section 171: maintaining and furnishing transfer pricing information and documents
Section 171 is the documentation backbone of the transfer pricing regime - it requires persons who have entered into an international transaction or specified domestic transaction, and constituent entities of international groups, to keep records and furnish them to the tax authorities on request or by a prescribed date.
Who must keep records, and what
Every person who has entered into an international transaction or specified domestic transaction, or who is a constituent entity of an international group, must keep and maintain such information and document in respect of it, for such period and in such manner, as may be prescribed.
Furnishing information on request
The Assessing Officer or the Commissioner (Appeals) may, during any proceeding under the Act, require a person who has entered into an international or specified domestic transaction to furnish the information or document within ten days from receipt of a notice.
On an application by that person, the Assessing Officer or Commissioner (Appeals) may extend this ten-day period by a further period not exceeding thirty days.
Furnishing by constituent entities of an international group
A constituent entity of an international group must furnish the prescribed information and document to the authority prescribed under Section 511(1), in the manner and by the date prescribed.
Key definitions
"Constituent entity" has the meaning assigned to it in Section 511(10)(d), and "international group" has the meaning assigned to it in Section 511(10)(g).
Frequently asked questions
How long does a taxpayer have to respond to a documentation request under Section 171?
Ten days from the date of receipt of the notice, which the Assessing Officer or Commissioner (Appeals) may extend by up to a further thirty days on application.
Does Section 171 apply only to taxpayers with international transactions?
No - it also applies to any person who is a constituent entity of an international group, and to persons with specified domestic transactions, not just international transactions.
Related sections
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Get help with transfer pricing documentation from our tax teamLast updated 9 September 2026