Services||Transfer Pricing

Master File & Country-by-Country (CbC) Reporting

Strengthening Global Tax Transparency & Transfer Pricing Compliance

With the implementation of the Base Erosion and Profit Shifting (BEPS) framework by the OECD, multinational enterprises (MNEs) are now required to maintain detailed and structured transfer pricing documentation. Two of the key components of this documentation are the Master File and Country-by-Country (CbC) Report—critical to promoting global tax transparency and avoiding disputes.

At [TAX WARRIOR], we offer specialized support to help MNEs prepare, maintain, and file these reports in compliance with Indian tax regulations under Section 92D of the Income Tax Act read with Rule 10DA and 10DB.

Master File Services Include:

Group-level business analysis

Documentation of TP policies and global value chain

Disclosure of intangibles and financing arrangements

Preparation and filing of Form 3CEAA

CbC Reporting Services Include:

Entity-wise revenue, profit, and tax analysis

Preparation of Form 3CEAD

Disclosure of intangibles and financing arrangements

Filing of Form 3CEAC (intimation of the reporting entity)

Frequently Asked Questions (FAQs)

1. Is CbC Reporting applicable to Indian subsidiaries?

Indian subsidiaries are not required to file CbC Reports themselves but must notify the Income Tax Department about the parent or alternate reporting entity.

2. What is the due date for filing Master File and CbC Report?

The Master File must be filed within 12 months from the end of the reporting accounting year. The CbC Report must be filed by the parent or alternate reporting entity based on their jurisdiction’s timelines.

3. What happens if I fail to file these reports?

Non-compliance may lead to penalties ranging from INR 500,000 to INR 500,000 per day of continued failure, along with potential scrutiny and legal consequences.

4. Can I use the same documentation for Master File and local file?

No, both have different formats and disclosure requirements. The Master File is group-level; the local file focuses on the Indian entity and its transactions.

5. How can your firm assist with CbC compliance?

We help with data collation, documentation, form filing, and strategic advisory to ensure your group remains fully compliant with Indian and international TP regulations.

Let’s Make Finance Simple, Together.

We’re here to make your financial journey smoother, more informed, and stress-free.

Services||Transfer Pricing

Master File & Country-by-Country (CbC) Reporting

Strengthening Global Tax Transparency & Transfer Pricing Compliance

Master File Services Include:

Group-level business analysis

Documentation of TP policies and global value chain

Disclosure of intangibles and financing arrangements

Preparation and filing of Form 3CEAA

CbC Reporting Services Include:

Entity-wise revenue, profit, and tax analysis

Preparation of Form 3CEAD

Disclosure of intangibles and financing arrangements

Filing of Form 3CEAC (intimation of the reporting entity)

Frequently Asked Questions (FAQs)

1. Is CbC Reporting applicable to Indian subsidiaries?

2. What is the due date for filing Master File and CbC Report?

3. What happens if I fail to file these reports?

4. Can I use the same documentation for Master File and local file?

5. How can your firm assist with CbC compliance?

Let’s Make Finance Simple, Together.

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