Direct Tax Laws & International Taxation · Latest Developments in International Taxation

Country-by-Country Reporting and Master File: Forms, Thresholds and Filers

Updated 5 October 2026 · Fact-checked

Transfer pricing documentation has three tiers: Local File (entity-level), Master File (group-level, Form 3CEAA) and Country-by-Country Report (Form 3CEAD). To solve a question, identify the group's revenue and the Indian entity's international transactions, test each threshold, then name the form, filer and due date.

Understand Country-by-Country Reporting and Master File

Transfer pricing documentation lets tax authorities check whether related parties priced their dealings at arm's length. After the OECD BEPS project (Action 13), the world adopted a three-tier structure. India follows it.

Tier 1 is the Local File. It is entity-specific. It holds details of the Indian entity's international transactions, the method used and the comparables. In India this is the documentation under Rule 10D of the transfer pricing rules plus the accountant's report (Form 3CEB). Detailed Local File documentation is not required if the aggregate value of the international transactions is ₹1 crore or less. Form 3CEB still applies. It is due one month before the return due date (for TP cases, return due 30 November, so Form 3CEB is due 31 October).

Tier 2 is the Master File. It gives a high-level view of the whole multinational group: structure, business, intangibles, financing and tax positions. Indian constituent entities file it in Form 3CEAA. Part A is filed by every Indian constituent entity of an international group. Part B is filed only when the thresholds are met.

Tier 3 is the Country-by-Country Report (CbCR). It shows, jurisdiction by jurisdiction, the group's revenue, profit, tax paid, employees, capital and assets. It is filed in Form 3CEAD by the parent entity, or an alternate reporting entity. It helps authorities spot profit shifting to low-tax places. It is a risk-assessment tool, not a basis for adjustment on its own.

The forms, thresholds and dates sit in the transfer pricing rules. Section numbers and form numbers have been renumbered across the law, so learn the logic: who files, when the threshold applies, which form, and the due date. Check the exact rule wording in your study material before the exam.

Key rules to remember

Master File threshold (both limbs for Part B): Group consolidated revenue (preceding accounting year) > ₹500 crore AND [the Indian constituent entity's international transactions in the relevant accounting year > ₹50 crore OR its intangible-related international transactions in that year > ₹10 crore]; The ₹50 crore and ₹10 crore tests apply to the Indian constituent entity's own transactions, not to the whole group. Revenue limb is mandatory. Then either the ₹50 crore limb or the ₹10 crore intangibles limb must be met.
CbCR threshold: Consolidated group revenue in the preceding accounting year > ₹6,400 crore for a group with an Indian parent; > ₹5,500 crore (EUR 750 million equivalent) for a group with a foreign parent; The rupee figure depends on whether the parent is Indian or foreign. The rule says revenue must exceed the figure, so revenue exactly equal to it does not trigger CbCR. Check the current rule for the exact amounts.
Master File form: Form 3CEAA (Part A: basic details of the entity and group; Part B: the master file content); Part A is filed by every Indian constituent entity of an international group, regardless of the thresholds. Part B is the full master file and is filed only when the thresholds are met. Both parts are due on or before 30 November following the end of the accounting year.
CbCR form: Form 3CEAD, filed by the parent entity or alternate reporting entity; Where the parent is outside India, an Indian constituent may have to file in specified situations. Form 3CEAB is a separate intimation by the Indian constituent entity giving details of the parent or alternate reporting entity (see the FAQ).
Master File due date: On or before 30 November following the end of the accounting year; This date applies to Parts A and B alike. For a year ending 31 March 2027, the due date is 30 November 2027.
CbCR due date: Within 12 months from the end of the reporting accounting year; For a year ending 31 March 2027, the due date is 31 March 2028.
Accountant's report (Form 3CEB): Required for any international transaction or specified domestic transaction; due one month before the return due date (for TP cases, return due 30 November, so Form 3CEB is due 31 October); Do not mix this with the Master File or CbCR. It is a separate compliance.

How to solve Country-by-Country Reporting and Master File questions

Use this order for any case on transfer pricing documentation. It stops you mixing the three tiers.

1Identify the entity: is it the Indian parent, an Indian subsidiary of a foreign group, or a standalone entity with no group? A standalone entity has no Master File or CbCR duty.
2Check whether an international group exists and note its consolidated revenue for the preceding accounting year.
3Note that Part A of Form 3CEAA is due from every Indian constituent entity of an international group, whatever the thresholds.
4Test Master File Part B: group revenue above ₹500 crore, plus the Indian entity's international transactions above ₹50 crore or its intangible-related transactions above ₹10 crore in the accounting year.
5Test CbCR: consolidated revenue exceeding ₹6,400 crore for an Indian parent, or exceeding ₹5,500 crore for a foreign parent. Then decide who files: the parent, an alternate entity, or an Indian constituent.
6Name the form (3CEAA, 3CEAD, or the intimation form 3CEAB) and the filing authority.
7State the due date from the year-end, and add any intimation timing.
8Check the Local File and Form 3CEB separately, since these apply even when the group thresholds fail. Local File documentation under Rule 10D is required for international transactions, but the detailed documentation is not required if their aggregate value is ₹1 crore or less. Form 3CEB still applies.
9Conclude in provision-fact-conclusion form and mention the consequence of default.

Quickest way: Three-gate test

When to use it: Use this for MCQs and short case questions where you must decide quickly which documents apply.

Gate 1: any international transaction? If yes, Form 3CEB is due. Local File documentation under Rule 10D is also required, but detailed documentation is not required if the aggregate value of the international transactions is ₹1 crore or less.
Gate 2: group revenue above ₹500 crore, with the Indian entity's international transactions above ₹50 crore or intangible-related transactions above ₹10 crore in the accounting year? If yes, Master File Part B. Part A is due from every Indian constituent entity regardless.
Gate 3: group revenue exceeding ₹6,400 crore (Indian parent) or exceeding ₹5,500 crore (foreign parent)? If yes, CbCR in Form 3CEAD.
Dates: Master File (Parts A and B) 30 November following the end of the accounting year; CbCR 12 months after the accounting year end; Form 3CEB one month before the return due date (31 October for TP cases, where the return is due 30 November).

Common mistakes in Country-by-Country Reporting and Master File

Applying the CbCR revenue limit to the Master File
Both documents relate to groups, so students mix the revenue limits.
Fix: Remember: Master File Part B starts at group revenue above ₹500 crore plus a transaction limit. CbCR applies when revenue exceeds ₹6,400 crore (Indian parent) or ₹5,500 crore (foreign parent).
Treating the ₹50 crore test as optional on its own, ignoring the revenue limit
Students remember only the transaction value and forget the group revenue condition.
Fix: Check revenue first. Without ₹500 crore group revenue, no Master File Part B arises even if transactions are large.
Ignoring the ₹10 crore intangibles limb
Students recall only ₹50 crore.
Fix: Add the alternative: the Indian entity's international transactions in intangible property above ₹10 crore also trigger Part B, provided the revenue condition is met.
Applying the transaction limits to the whole group
Students see 'group' in the revenue test and carry it into the transaction test.
Fix: The ₹50 crore and ₹10 crore tests are for the Indian constituent entity's own international transactions in the accounting year.
Thinking Part A of Form 3CEAA depends on the thresholds
Students treat the whole of Form 3CEAA as one filing.
Fix: Part A is filed by every Indian constituent entity of an international group. Only Part B depends on the thresholds.
Saying the Indian subsidiary always files CbCR
Students forget the parent or alternate entity is the primary filer.
Fix: The parent entity files Form 3CEAD. An Indian constituent files only in the specified situations. Form 3CEAB is a separate intimation giving details of the parent or alternate reporting entity. It is not a prior intimation to file the CbCR.
Counting the due date from the wrong year-end
Master File is fixed to 30 November after the year-end; CbCR runs 12 months from the group's accounting year-end.
Fix: Write the year-end first, then add the period. Master File: 30 November following the end of the accounting year. CbCR: 12 months after the reporting accounting year.
Confusing Form 3CEB with Master File or CbCR
All are TP compliances with similar form numbers.
Fix: Form 3CEB is the accountant's report on international transactions. Form 3CEAA is the Master File. Form 3CEAD is the CbCR.

Worked examples

Example 1

Alpha India Ltd is part of a foreign group. For the preceding accounting year the group's consolidated revenue was ₹4,200 crore. In the relevant accounting year Alpha India's international transactions total ₹62 crore, none of which relates to intangibles. Which documents apply and what is the Master File due date?

Show the solution

Alpha India is an Indian constituent entity of an international group, so it files Part A of Form 3CEAA regardless of the thresholds.
Group revenue is ₹4,200 crore, which is above ₹500 crore, so the revenue limb of the Part B test is met.
Alpha India's own international transactions are ₹62 crore, which is above ₹50 crore, so the transaction limb is also met. Part B applies.
CbCR needs consolidated revenue exceeding ₹5,500 crore for a foreign-parent group. ₹4,200 crore does not exceed that, so no CbCR obligation arises.
Alpha India has international transactions, so Form 3CEB and Local File duties also apply.
The Master File (Parts A and B alike) is due on or before 30 November following the end of the relevant accounting year. For a year ending 31 March 2027, that is 30 November 2027.

Answer: Alpha India must file the Master File (Form 3CEAA, Parts A and B) on or before 30 November following the end of the relevant accounting year, along with Form 3CEB and the Local File. No CbCR is required because group revenue does not exceed ₹5,500 crore.

Example 2

Bharat Ltd, an Indian company, is the parent of a multinational group with consolidated revenue of ₹7,000 crore for the accounting year ended 31 March 2027. Which form must it file for CbCR, who files it, and by when?

Show the solution

Consolidated revenue of ₹7,000 crore is above the ₹6,400 crore threshold for a group with an Indian parent, so the obligation arises.
Bharat Ltd is the parent entity resident in India, so it is the reporting entity.
The report is filed in Form 3CEAD, covering revenue, profit, tax and other details for each jurisdiction.
The due date is 12 months from the end of the reporting accounting year, that is 31 March 2028.
Separately, the group's revenue is above ₹500 crore, so Master File Part B also needs checking against Bharat Ltd's own transaction limits.

Answer: Bharat Ltd, as the Indian parent, files Form 3CEAD by 31 March 2028. Master File Part B applies too if its own transaction limit is met.

Exam tips

Write thresholds as numbers with the word 'crore' and the exact condition. Examiners award marks for the precise limits.
In a case question, first state the group revenue test, then the Indian entity's transaction test. This matches how marks are allotted.
For CbCR, say whether the parent is Indian or foreign before quoting the threshold.
Learn the three-tier names in order: Local File, Master File, CbCR. Many questions ask you to differentiate them.
For 'differentiate Master File and CbCR' answers, use points: content, filer, form, threshold, due date.
Keep Forms 3CEAA, 3CEAB, 3CEAD and 3CEB separate in your notes, and recheck the rule wording in the latest study material.

Practice questions from Latest Developments in International Taxation

Country-by-Country Reporting and Master File: frequently asked questions

What is the difference between CbCR and Master File?

The Master File gives a group-wide narrative: structure, business lines, intangibles, financing and tax positions. CbCR gives numbers for each country: revenue, profit, tax paid, employees and assets. They have different thresholds, forms and due dates.

Which forms do I need to remember for CbCR and Master File?

Remember Form 3CEAA for the Master File and Form 3CEAD for the CbCR. Form 3CEB is the accountant's report on international transactions. Form 3CEAB is the intimation by an Indian constituent entity of an international group giving details of the parent or alternate reporting entity. It is due at least two months before the CbCR due date. It is not a prior intimation to file the CbCR.

What is the Master File threshold?

For Part B of Form 3CEAA, the group's consolidated revenue in the preceding accounting year must exceed ₹500 crore. Also, the Indian constituent entity's international transactions in the relevant accounting year must exceed ₹50 crore, or its intangible-related international transactions must exceed ₹10 crore. Part A is filed by every Indian constituent entity of an international group, regardless of these thresholds.

Who files the CbCR in India?

The parent entity, or an alternate reporting entity, files it when group revenue exceeds the threshold. The threshold is ₹6,400 crore for a group with an Indian parent and ₹5,500 crore for a group with a foreign parent. An Indian constituent entity may have to file in specified cases where the parent is outside India. Separately, an Indian constituent entity gives details of the parent or alternate reporting entity in Form 3CEAB at least two months before the CbCR due date.