The Union Budget 2026 has expanded the definition of “accountant” under the Safe Harbour Rules governing international transactions. The amendment formally brings Cost and Management Accountants (CMAs) within the ambit of Safe Harbour certification, marking a long-awaited policy shift.
What Has Changed?
As per the updated definition under the Safe Harbour Rules (Rules 87 to 93 of the Income-tax Rules), the term “accountant” now includes:
- Persons recognised for undertaking cost certification, in addition to those already covered under Section 515(3)(b) of the Income-tax Act.
- Professionals recognised by the government of the country where the associated enterprise (AE) is registered or incorporated, subject to prescribed conditions.
This expansion allows recognition not only of Indian professionals but also of qualified professionals from the AE’s home jurisdiction, thereby aligning India’s transfer pricing framework with global business realities.
Key Eligibility Conditions
The revised rules lay down specific experience and turnover thresholds:
- Individuals practising independently must have at least 10 years of professional experience and annual receipts exceeding ₹50 lakh in the preceding year.
- Where the professional is a partner or member of an entity providing accountancy or valuation services, the entity’s annual receipts must exceed ₹3 crore.
- In the case of foreign-recognised professionals, the entity or its affiliates must have a presence in more than two countries, in addition to meeting experience and turnover criteria.
Big Win for CMAs
The amendment is being widely seen as a major win for the CMA community, as Cost and Management Accountants are now officially authorised to undertake Safe Harbour certifications for eligible international transactions. This change acknowledges the growing role of CMAs in cost analysis, valuation, and transfer pricing documentation.
