# Master File & Country-by-Country Reporting

> Indian entities of multinational groups file a master file (Form 3CEAA, now Form 56 under the 2025 Act) when consolidated group revenue exceeds ₹500 crore and related-party transactions cross set thresholds, and constituent entities of groups with consolidated revenue of ₹6,400 crore or more file or notify country-by-country reporting (Form 3CEAD, now Form 59). These give tax authorities a group-wide view of where profits, people and taxes sit.

Practice: Transfer Pricing — https://www.industax.com/services/transfer-pricing/

Most Indian subsidiaries of foreign groups rely on the parent's CbCR filed abroad and only file an intimation in India, but the master file usually needs Indian filing with group information.

We coordinate with the group's tax team to prepare the Indian filings and intimations on time.

## Key facts

| Item | Detail |
| --- | --- |
| Master file | Form 56 (formerly 3CEAA) |
| CbCR | Form 59 (formerly 3CEAD); group revenue ≥ ₹6,400 crore |
| Master file trigger | Group revenue > ₹500 crore plus transaction thresholds |
| Intimations | Where parent files CbCR abroad |

## Who needs this

- Indian entities of large multinational groups
- Indian-headquartered multinationals
- Group tax teams

## What's included

- Applicability analysis
- Master file and CbCR filings
- Intimations

## Documents

- Group structure and financials
- Parent's CbCR details
- Global TP policy

## Process

1. **Assess** — Thresholds tested.
2. **Prepare** — Group data compiled.
3. **File** — Forms and intimations submitted.

## FAQs

### Does every foreign subsidiary need a master file?

No. It applies only when group revenue and the entity's international transactions exceed the prescribed thresholds.

### Who files CbCR for a foreign-parented group?

Usually the ultimate parent in its home country, with Indian entities filing an intimation; Indian filing is needed in certain cases, such as when the parent's country doesn't exchange reports with India.

### Are there penalties for not filing?

Yes. Non-filing of the master file or CbCR attracts significant penalties, including daily penalties for continuing default.

## Official sources

- Income Tax Department — Transfer Pricing: https://www.incometaxindia.gov.in/

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Canonical page: https://www.industax.com/services/transfer-pricing/master-file-cbcr
Publisher: Indus Tax — CA-led tax and compliance firm (https://www.industax.com). Contact: info@industax.com, 9059139258.
This is general information, not advice for your specific facts.