A GCC's single largest tax exposure is usually not corporate tax itself, it's getting the related-party pricing to its own parent wrong. Here's what's actually in force for FY 2025-26, and what's still on the drawing board.
What's in force now
CBDT's notification of 25 March 2025 extended the Safe Harbour Rules to cover FY 2024-25 and FY 2025-26, and raised the eligibility threshold for covered services (the category most GCCs fall under) from ₹200 crore to ₹300 crore in transaction value. Separately, CBDT Notification No. 157/2025, dated 6 November 2025, fixed the arm's-length tolerance range for AY 2025-26 at 1% for wholesale trading transactions and 3% for all other transaction types, the band within which a related-party price is accepted without further adjustment.
What that means in practice
If your GCC's covered-service transactions with its parent stay under the ₹300 crore threshold, electing into the safe harbour trades a small amount of pricing flexibility for real certainty: no comparability study, no benchmarking dispute, an agreed margin. Above that threshold, or outside the eligible service categories, the standard arm's-length process applies: Form 3CEB, a transfer pricing study, and a local file, filed alongside the corporate tax return.
What's proposed, not yet law
Draft changes floated for FY 2026-27 would consolidate several IT and ITeS service categories under a single margin (reported at 15.5%) and raise the eligibility threshold further, to ₹2,000 crore. Until notified and in force, we plan against the current rules above, not the proposed ones, and we'll update this briefing when that changes.
The full context, including how this fits into a GCC's annual compliance calendar, is on our Tax & Transfer Pricing page.
This article is general information, not tax or legal advice for your situation. Speak with a qualified adviser before acting.