Master File & Country-by-Country Reporting

Group-level documentation for large multinational structures — assessed, prepared and filed for Indian constituent entities under Rule 10DA and 10DB.

Overview

The BEPS Action 13 three-tier framework

Alongside the entity-level Local File, large multinational groups must prepare a Master File (group-wide business and financial overview) and, for the very largest groups, a Country-by-Country Report breaking down revenue, profit and tax by jurisdiction.

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Who this applies to

Indian constituent entities of groups with consolidated revenue above ₹500 crore (Master File) or roughly ₹6,400 crore (CbCR).

What We Cover

Every Master File and CbCR filing

Threshold Assessment

Annual applicability testing under Rule 10DA and 10DB as group revenue changes.

Master File Part A & B

Basic group information and the detailed report, prepared and filed via Form 3CEAA.

CbCR Intimation

Form 3CEAC filing specifying the reporting entity and jurisdiction.

CbCR Report

Form 3CEAD preparation and filing within 12 months of year-end.

Our Process

Coordinated across your global tax function

Step 1

Threshold Test

Assess consolidated group revenue and transaction thresholds each year.

Step 2

Data Collection

Coordinate with global tax/finance teams for group-wide data.

Step 3

Preparation

Draft Master File and CbCR content in the prescribed format.

Step 4

Filing

Submit Forms 3CEAA/3CEAC/3CEAD before statutory deadlines.

Why Work With Us

One less global compliance thread to track yourself

Annual Threshold Tracking

We flag applicability changes before they become a compliance gap.

Global Coordination

Direct liaison with your overseas tax function.

On-Time, Every Time

Calendarised filing well ahead of statutory deadlines.

FAQs

Common questions

What's the penalty for missing a Master File filing? +

A penalty of ₹5 lakh applies for failure to furnish the Master File where applicable.

Does an Indian subsidiary of a foreign parent ever need to file CbCR itself? +

Yes, in certain secondary-filing scenarios — for example if the parent's jurisdiction has no exchange arrangement with India, or fails to file.

Not sure if Master File or CbCR applies to your group?

We'll assess your threshold, free.