—Guide
Master File and CbCR in India: Thresholds, Forms and Deadlines
When Indian entities of multinational groups must file a master file or deal with Country-by-Country Reporting, the thresholds, forms and deadlines.
Following the OECD's BEPS project, India introduced a three-tier transfer pricing documentation structure for multinational groups: the local file (the entity's own TP study), a master file, and the Country-by-Country Report (CbCR). This guide explains the second and third tiers.
Note: this describes the requirements under the Income-tax Act, 1961 and rules. Successor provisions apply under the Income-tax Act, 2025.
The Master File
A master file gives an overview of the group's global business: its structure, business description, intangibles, intercompany financing, and financial and tax positions, including its transfer pricing policies.
Who files it
- Every constituent entity of an international group files a basic part of the master file form.
- The full master file is required where the group's consolidated revenue exceeds ₹500 crore and the Indian entity's international transactions exceed ₹50 crore, or its transactions relating to intangible property exceed ₹10 crore.
Due date
Generally by the due date of the income-tax return.
Country-by-Country Report
The CbCR shows, for each country where the group operates, revenue, profit before tax, tax paid and accrued, capital, retained earnings, employees and tangible assets, along with the entities and their main activities.
Who files it
Groups with consolidated revenue at or above the threshold — ₹6,400 crore, aligned with €750 million. The ultimate parent files in its home country, and the report is exchanged with other countries.
Indian entities of foreign groups
Indian constituent entities notify details of the reporting entity in the prescribed form. In certain circumstances, such as where information exchange isn't available, local filing in India may be required.
Due date
Generally within 12 months of the end of the group's reporting year.
Penalties
Penalties for failures relating to the master file and CbCR can be significant, including daily penalties for continuing defaults.
Getting Help
Think Filing helps Indian entities of multinational groups meet master file and CbCR obligations, working with group tax teams.