Why Master File and CbCR exist

As part of the OECD's BEPS Action 13 framework, India introduced a three-tiered transfer pricing documentation structure: the Local File (entity-level, already familiar under Rule 10D), the Master File (group-level business and financial overview), and the Country-by-Country Report (a jurisdiction-by-jurisdiction breakdown of revenue, profit and tax for very large multinational groups). Together they give tax authorities a complete picture — from the transaction level up to the global group level.

Who must file the Master File (Form 3CEAA)?

Under Rule 10DA, an Indian constituent entity of an international group must file a Master File where, broadly:

  • The consolidated group revenue exceeds ₹500 crore, and
  • Either the aggregate value of international transactions exceeds ₹50 crore, or transactions involving intangible property exceed ₹10 crore.

The Master File is filed in two parts: Part A (basic group information, filed by every constituent entity meeting a lower threshold) and Part B (the detailed report, filed by a designated entity where the above thresholds are met).

Who must file CbCR (Forms 3CEAC / 3CEAD)?

Under Section 286 and Rule 10DB, Country-by-Country Reporting applies to international groups with total consolidated group revenue exceeding the prescribed threshold — approximately ₹6,400 crore (aligned to the OECD's €750 million benchmark). Where applicable:

  • Form 3CEAC — an intimation specifying which group entity will file the CbCR and in which jurisdiction, due at least two months before the CbCR filing deadline.
  • Form 3CEAD — the actual Country-by-Country Report, due within 12 months of the end of the reporting accounting year (for the Indian parent entity, or an Indian constituent entity under specified secondary-filing circumstances).
Even where the ultimate parent entity is overseas, an Indian subsidiary may still have a CbCR filing obligation if the foreign parent's jurisdiction has no exchange arrangement with India, or fails to file.

Due dates at a glance

  • Master File (Form 3CEAA): on or before the due date of filing the income tax return (typically November 30 for entities with international/specified domestic transactions).
  • CbCR Intimation (Form 3CEAC): at least 2 months prior to the CbCR due date.
  • CbCR Report (Form 3CEAD): within 12 months from the end of the reporting accounting year.

Penalties for non-compliance

Failure to furnish the Master File attracts a penalty of ₹5 lakh. CbCR non-compliance is tiered and can escalate significantly for continuing default — starting at ₹5,000 per day and rising to ₹15,000 or ₹50,000 per day depending on the duration and nature of the failure, alongside penalties for furnishing inaccurate information.

How we help

We assess applicability each year as your group's revenue and transaction profile changes, prepare Part A and Part B of the Master File, coordinate with your global tax function for CbCR intimation and reporting, and ensure every filing lands before its statutory deadline.