—International Taxation & Transfer Pricing
Transfer Pricing Certification, Master File & CbCR
Accountant's report on international transactions, Master File and Country-by-Country Reporting.
Handled by a practising Chartered Accountant or Company Secretary.
Scope of work
Accountant's report on international transactions, Master File and Country-by-Country Reporting.
Key deliverables
- Accountant's report
- Master File
- CbCR filings
Governing law
Income-tax Act (1961 / 2025, as applicable to the period) (transfer pricing provisions)
Frequency
Annual
REGISTRATION ONLY
Transfer Pricing Certification, Master File & CbCR
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- Accountant's report
- Master File
- CbCR filings
REGISTRATION + COMPLIANCE CARE
Transfer Pricing Certification, Master File & CbCR + Compliance Care
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+ ₹9,599/yr for year-one ROC compliance
- Accountant's report
- Master File
- CbCR filings
- Financial statements in Schedule III format
- Board report and AGM notice
- Filed AOC-4 with SRN
- Filed MGT-7 / MGT-7A with SRN
- Board and AGM minutes
500+
Companies incorporated
100%
CA/CS-signed filings
4.8/5
Founder rating
—A closer look
Understanding TP certification, master file, and CbCR
Everything below is written for multinational groups and their Indian entities — the annual TP accountant's report, and the master file and Country-by-Country reporting rules.
What is TP certification, master file, and CbCR?
Every year, a company with international transactions with associated enterprises must obtain a Chartered Accountant's report certifying the transactions and their arm's length pricing, and file it before the income-tax return. This is the accountant's report in Form 3CEB.
Larger multinational groups have two further layers, based on OECD standards: a master file describing the group's global business and transfer pricing, and a Country-by-Country Report (CbCR) showing revenue, profit, tax, and activity in each country.
The key terms
The three reports and their thresholds:
- Accountant's report (Form 3CEB)
- Required for every entity with international or specified domestic transactions, certifying details and arm's length pricing. Due one month before the return due date.
- Master file (Form 3CEAA)
- Required for Indian constituent entities of groups with consolidated revenue above ₹500 crore, where their international transactions exceed ₹50 crore, or intangible-related transactions exceed ₹10 crore.
- Short-form master file
- Other constituent entities of international groups file a basic part of the master file form.
- CbCR (Form 3CEAD)
- Required for groups with consolidated revenue at or above the threshold (₹6,400 crore, aligned with €750 million), filed by the parent or an alternate reporting entity.
- CbCR notification (Form 3CEAC)
- Indian constituent entities of foreign groups notify details of the reporting entity.
- Local file
- The entity's own transfer pricing documentation — the TP study — which supports the accountant's report.
- Penalties
- Significant penalties apply for failing to file these reports or furnishing inaccurate information.
A simple example
A Hyderabad subsidiary of a European pharma group with over €1 billion revenue has ₹180 crore of international transactions with group companies. Each year, it obtains its TP study and files Form 3CEB before its return. Because the group is above ₹500 crore and its transactions exceed ₹50 crore, it also files the full master file in Form 3CEAA, using group-level information from the parent. Because the group is above the CbCR threshold, it files Form 3CEAC confirming that the parent files the CbCR in its home country, which India receives through information exchange.
Why it matters
These reports carry some of the heaviest penalties in the tax system:
- Mandatory annual filing
- Form 3CEB is required every year you have reportable transactions.
- Deadlines before the return
- Form 3CEB is due before the return, so it drives the whole year-end timetable.
- Penalties
- Failure to furnish the accountant's report, master file, or CbCR-related forms can attract substantial penalties.
- Consistency
- Tax officers compare the accountant's report, master file, and CbCR for inconsistencies.
- Global visibility
- CbCR data is exchanged between countries and used in risk assessment.
- Group coordination
- Master file and CbCR need group-level data, which takes time to obtain.
- Accuracy
- Errors in reported transactions or relationships can lead to penalties and adjustments.
Who is this for?
- Any company with international transactions with associated enterprises
- Indian subsidiaries of multinational groups
- Indian-headquartered groups with foreign subsidiaries
- Constituent entities of groups above the master file or CbCR thresholds
- Companies with specified domestic transactions above the threshold
The TP study (local file) is covered by our Transfer Pricing Study & Documentation service; this service covers the annual certification and group-level reports.
The reports compared
Who files what:
| Aspect | Form 3CEB | Master file | CbCR |
|---|---|---|---|
| Who | Any entity with international or specified domestic transactions | Constituent entities of larger international groups | Groups above the CbCR revenue threshold |
| Content | Transactions and arm's length certification | Group structure, business, intangibles, financing, TP policies | Country-level revenue, profit, tax, employees |
| Prepared by | A Chartered Accountant | The entity, using group information | The parent or alternate reporting entity |
| Timing | One month before the return due date | Around the return due date | Within 12 months of the group's year end |
What we'll need from you
- TP study
- The entity's transfer pricing documentation for the year.
- Transaction data
- Values of all international and specified domestic transactions.
- Audited accounts
- The entity's audited financial statements.
- Group information
- Group structure, business description, and policies for the master file.
- Group revenue
- Consolidated revenue, to test master file and CbCR thresholds.
- Reporting entity details
- Who files the CbCR and where, for Form 3CEAC.
Fees depend on the group's size and the reports required.
How we handle the annual cycle
Each year:
- 1
Test thresholds
We check which reports apply, based on transactions and group revenue.
- 2
Finalise the TP study
Transactions are analysed and the local file completed.
- 3
Certify Form 3CEB
A CA reviews transactions and pricing and issues the accountant's report.
- 4
Gather group data
Master file information is obtained from the parent.
- 5
File group reports
Master file and CbCR-related forms are filed by their due dates.
- 6
Reconcile
Reports are checked for consistency with each other and the return.
After filing
The reports feed into assessment:
- Keep support
- Keep the documentation supporting each report.
- Watch for TP scrutiny
- Transfer pricing cases may be referred to specialist officers.
- Align with the group
- Keep Indian reports consistent with group filings elsewhere.
- Plan next year early
- Request group data well before deadlines.
- Monitor thresholds
- Group growth can bring new reports into scope.
- Apply the new Act
- From tax year 2026-27, apply the Income-tax Act, 2025's corresponding provisions and forms.
Benefits and responsibilities
Benefits
- The right reports filed on time
- Accurate Form 3CEB certification
- Master file and CbCR obligations met
- Consistent reporting across India and the group
- No threshold surprises
Responsibilities
- Share all related-party transactions
- Obtain group information in time
- Keep the TP study current
- Meet each report's deadline
- Keep reports consistent with each other
- Tell us about group changes
—FAQ
Questions finance teams actually ask us
Yes, if they have international transactions with associated enterprises, regardless of size. The detailed documentation threshold is separate, but the accountant's report is still required.