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.
Related Guides
Key Facts About Master File and CbCR
- Applies in: All states across India, under the relevant central law.
- Mode: Mostly online via the official government portal.
- Typical timeline: Ranges from a few days to a few weeks depending on the case.
- Non-compliance: May attract penalties, interest or late fees.
- Expert help: TaxClue completes the entire process end to end for you.
What is the master file?
The master file is a group-level document giving a high-level overview of a multinational group’s business, intangibles, intercompany finance and tax positions. In India it is filed in Form 3CEAA, with an intimation of the designated filer in Part A.
What is CbCR?
Country-by-Country Reporting is a table of the group’s revenue, profit, tax paid, capital, employees and assets in each country. The parent (or surrogate) files it in Form 3CEAD; Indian constituent entities intimate details in Form 3CEAC.
Over 90% of compliance penalties in India arise from missed due dates — timely handling can save businesses thousands of rupees each year.
Master File and CbCR: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.