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.
Direct Answer
Master File and CbCR filing services cover Form 3CEAA (Master File), Form 3CEAC (CbCR intimation) and Form 3CEAD (the Country-by-Country Report) for Indian constituent entities of large multinational groups under Rule 10DA and 10DB.
The BEPS Action 13 three-tier framework
India's transfer pricing documentation framework follows the three-tier approach introduced through BEPS Action 13. The Local File supports the Indian entity's individual related-party transactions. The Master File gives tax authorities a group-wide view of the multinational enterprise, while the Country-by-Country Report presents jurisdiction-wise financial and operational data for the largest groups.
The Master File generally covers the group's legal and ownership structure, important business lines, supply chains, key profit drivers, intangibles, financing arrangements, consolidated financial statements and important tax rulings or Advance Pricing Agreements. CbCR reports revenue, profit before tax, tax paid and accrued, employees, stated capital, accumulated earnings, tangible assets and principal activities by jurisdiction.
These filings allow tax authorities to compare the Indian Local File with the group's global facts. Inconsistent descriptions of functions, ownership of intangibles, financing arrangements or profit allocation may trigger questions even where the underlying Indian transaction appears properly benchmarked.
Our Master File CbCR filing services India process therefore focuses not only on submission, but also on consistency across Form 3CEAA, Form 3CEAC, Form 3CEAD, the Local File, Form 3CEB and the group's global documentation.
We also review exchange-of-information arrangements, reporting-entity status, Indian constituent entity details and prior-year filing positions so that changes in group structure or jurisdiction do not create an overlooked notification or secondary-filing requirement.
This creates a repeatable annual compliance process with clear ownership, review checkpoints and documented filing evidence.
Who this applies to
Indian constituent entities of international groups that cross the prescribed group-revenue and transaction thresholds under Rule 10DA or the CbCR revenue threshold under Section 286 and Rule 10DB.
Indian subsidiaries of foreign-parented groups may also have intimation, designated-entity or secondary-reporting obligations even where the ultimate parent files outside India.
Every Master File and CbCR filing
We assess applicability annually, prepare the prescribed content and coordinate Indian filing with the group's overseas reporting timetable.
Threshold Assessment
We test consolidated group revenue, aggregate international transactions and intangible transaction values under Rule 10DA, then separately review the CbCR threshold and reporting structure under Rule 10DB.
Master File Part A & B
We prepare or localise Form 3CEAA information, including group structure, businesses, supply chains, services, intangibles, financing, financial statements and relevant tax agreements.
CbCR Intimation
We support Form 3CEAC filing to identify the parent entity or alternate reporting entity, its jurisdiction and the expected route through which India will receive the report.
CbCR Report
We assist with Form 3CEAD preparation, data mapping, validation and filing within the statutory timeline, including secondary-filing analysis where the reporting parent is overseas.
Designated Indian constituent entity support
Where an international group has more than one Indian constituent entity, one entity may be designated to furnish the Master File information. We coordinate entity data, support the relevant intimation process and ensure that the filing reflects the functions and transactions of all Indian group entities consistently.
Coordinated across your global tax function
A single compliance calendar links Indian deadlines with the parent entity's global reporting cycle.
Threshold Test
We document the relevant accounting year, consolidated revenue, international transaction values, intangible transaction values and group reporting structure before confirming the applicable forms.
Data Collection
We issue structured information requests to Indian and overseas finance, tax, legal and business teams, then reconcile entity names, activities, financial data and jurisdictional classifications.
Preparation
We draft or review the Master File and CbCR content, map global information into the Indian forms and check consistency with financial statements, Local Files and transfer pricing policies.
Filing
We coordinate portal preparation, management review, verification and timely submission of Form 3CEAA, Form 3CEAC and Form 3CEAD, then preserve acknowledgements and final records.
One less global compliance thread to track yourself
Annual Threshold Tracking
We reassess applicability each year as consolidated revenue, transaction values, group ownership and reporting jurisdictions change.
Global Coordination
We liaise with overseas tax teams and advisers to obtain the correct global content without duplicating work or creating conflicting descriptions.
Consistency Review
Master File, CbCR, Local File, Form 3CEB and financial information are reviewed together before filing to reduce avoidable assessment risk.
Common questions
Not sure if Master File or CbCR applies to your group?
We'll assess your thresholds and Indian filing obligations.
Related: TP Documentation · Master File & CbCR (Blog)