Master File and CbCR explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
The Master File (Form 3CEAA) and Country-by-Country Report (Form 3CEAD) are the top two tiers of India’s BEPS Action 13 documentation. They give tax authorities a group-wide view of operations, profits and taxes, and apply only to large multinational groups above notified revenue and transaction thresholds.
Overview
Following OECD BEPS Action 13, India adopted a three-tier transfer pricing documentation model — the local file (the TP study), the Master File and the Country-by-Country Report. The rules sit in the transfer pricing provisions of the Income-tax Act, 2025 (originally section 92D and 286, with Rules 10DA and 10DB). Only the largest groups reach the top two tiers.
The Master File
The master file gives a blueprint of the whole multinational group: organisational structure, description of businesses, intangibles and their ownership, intercompany financing arrangements, and the group’s consolidated financial and tax positions. It is designed so a tax officer can place the Indian entity within the group’s value chain.
- Form 3CEAA Part A: basic details, filed by every constituent entity of an international group (no threshold).
- Form 3CEAA Part B: the full master file, filed only when thresholds are crossed.
- Form 3CEAB: intimation of the designated entity where several Indian constituents exist, filed 30 days before the master-file due date.
Master File Thresholds
Part B applies where the group’s consolidated revenue exceeds ₹500 crore and either:
- the aggregate value of international transactions exceeds ₹50 crore, or
- international transactions in intangibles / royalty exceed ₹10 crore.
Country-by-Country Report (CbCR)
The CbCR is a standardised table showing, for each tax jurisdiction where the group operates: revenue (related and unrelated), profit before tax, income tax paid and accrued, stated capital, accumulated earnings, number of employees and tangible assets, plus a list of constituent entities and their activities. It lets authorities assess high-level BEPS risk.
| Form | Purpose | Filed by |
|---|---|---|
| Form 3CEAC | Intimation of parent/alternate reporting entity | Indian constituent entity of a foreign-parented group |
| Form 3CEAD | The CbC report itself | Indian parent, or Indian constituent under secondary filing |
| Form 3CEAE | Intimation of designated filer where multiple Indian constituents | Group |
CbCR Threshold
CbCR applies where the group’s consolidated revenue exceeds the notified limit — currently around ₹6,400 crore (aligned to the €750 million OECD threshold). Verify the current rupee figure, as it tracks an exchange-rate-linked notification.
Filing Timeline
- Form 3CEAA (master file): generally by the income-tax return due date.
- Form 3CEAC (intimation): at least two months before the CbCR due date.
- Form 3CEAD (CbCR): within 12 months of the group’s reporting accounting year end.
Secondary / Local Filing
Normally the ultimate parent files CbCR in its home country and the report is exchanged with India under a treaty. But if there is no exchange arrangement, or a systemic failure of exchange, an Indian constituent entity may have to file the CbCR locally (Form 3CEAD).
Common Pitfalls
- Missing Form 3CEAA Part A, which every group constituent must file regardless of size.
- Overlooking the intimation forms (3CEAB / 3CEAC), which fall due before the main forms.
- Assuming the foreign parent’s filing covers India without checking the exchange relationship.