Master File (Form 3CEAA) and Country-by-Country Report Filing
For Indian entities of international groups. We confirm which forms apply to you, collect the group data, and file Form 3CEAA, the intimations and the CbC report on time.
Starts at ₹4,999 + GST, Part A of Form 3CEAA
What are the master file and the CbC report?
India adopted the three-tier transfer pricing documentation of the OECD's BEPS Action 13: a local file (the TP study under Rule 10D), a master file that describes the whole group, and a country-by-country (CbC) report that shows where the group earns its revenue and profit and pays its tax.
The master file is filed in Form 3CEAA under section 92D(4) and Rule 10DA. The CbC report is filed in Form 3CEAD under section 286 and Rule 10DB. From tax year 2026-27 these become Forms 56 and 59 under sections 171(4) and 511 of the Income-tax Act, 2025.
Master file: Part A and Part B
- Part A is filed by every Indian constituent entity of an international group, even a small one, and even without a large international transaction value
- Part B is required only when the group's consolidated revenue is above ₹500 crore and the entity's international transactions are above ₹50 crore, or its transactions in intangible property are above ₹10 crore
- Form 3CEAA is due by the return due date. For FY 2025-26 that is 30 November 2026
CbC report
- Applies when the group's consolidated revenue for the preceding accounting year is ₹6,400 crore or more
- An Indian parent, or an Indian entity named as alternate reporting entity, files Form 3CEAD within 12 months from the end of the reporting year
- An Indian entity of a foreign-parented group files Form 3CEAC at least two months before the CbC report is due, naming the entity that will report
Why groups use FilingBase
We test the thresholds for your group before any form is filed, so you file what is needed and nothing else.
We work with your parent's tax team and translate their data into the Indian forms.
3CEAB, 3CEAC, 3CEAA and 3CEAD each have their own deadline. We diarise all of them.
Part A and the intimations have published prices. Part B and CbCR are quoted in writing first.
Documents required
Group information
- Legal and ownership chart of the group
- Description of the group's business and main value drivers
- Consolidated financial statements of the parent
- List of entities in the group with country of residence
For Part B and CbCR
- Group transfer pricing policies and intercompany financing
- Intangibles owned, with the owning entity
- APAs and tax rulings in force
- Revenue, profit, tax paid, employees and assets by country
Not sure which package fits?
A specialist will map your situation to the right plan in one call.
How we file
- Threshold check
We confirm whether Part A, Part B, intimations or the CbC report apply to your entity for the year.
- Intimations
Form 3CEAB is filed at least 30 days before the master file due date, and Form 3CEAC two months before the CbC due date.
- Data collection
We gather the group data from you or your parent's tax team, mapped to each field of the form.
- FilingAcknowledgement shared
Form 3CEAA is filed by the return due date, and Form 3CEAD within 12 months of the year end.
Transparent pricing
Master file Part A
₹4,999
Every Indian entity of an international group
- Group and entity details compiled
- Part A of Form 3CEAA prepared
- Filed on the e-filing portal
- Part B data
Intimation
₹1,999
Form 3CEAB or 3CEAC, per filing
- Applicability checked
- Designated or reporting entity confirmed
- Form prepared and filed
Part B and CbC report
Quoted
Large groups only
- Master file Part B narrative
- Form 3CEAD country-by-country data
- Coordination with group tax team
- Fee agreed in writing first
All prices are professional fees exclusive of GST at 18%. There is no government fee for these forms.
Master file and CbC forms, old and new numbers
| Form up to FY 2025-26 | Form from tax year 2026-27 | Who files it |
|---|---|---|
| Form 3CEAA | Form 56 | Every Indian constituent entity of an international group (Part A); Part B above the thresholds |
| Form 3CEAB | Form 57 | The Indian entity designated to file the master file, where the group has more than one in India |
| Form 3CEAC | Form 58 | An Indian entity whose parent is outside India, intimating the CbC reporting entity |
| Form 3CEAD | Form 59 | The Indian parent or alternate reporting entity, or an Indian entity required to file locally |
| Form 3CEAE | Form 60 | Intimation on behalf of the international group |
Source: Income Tax Department, FAQs and guidance notes on forms as per the Income-tax Rules, 2026.
Due dates and penalties for FY 2025-26
| Form | Due date for FY 2025-26 |
|---|---|
| Form 3CEAB (designated entity intimation) | At least 30 days before the Form 3CEAA due date, so by 31 October 2026 |
| Form 3CEAA (master file) | 30 November 2026, the return due date |
| Form 3CEAC (CbC intimation) | At least two months before the Form 3CEAD due date |
| Form 3CEAD (CbC report) | Within 12 months from the end of the reporting accounting year |
Penalties
- Master file not furnished: ₹5,00,000 under section 271AA(2)
- CbC report not furnished: ₹5,000 a day for the first month, ₹15,000 a day after that, and ₹50,000 a day after a penalty order, under section 271GB
- Inaccurate particulars in the CbC report: ₹5,00,000
Master file and local file are different
The master file describes the group. The local file, or TP study, tests your own transactions. Most Indian entities of international groups need both Part A of the master file and Form 3CEB, and the TP study when their international transactions are above ₹1 crore. See our transfer pricing services and Form 3CEB filing.
Frequently asked questions
Who has to file Form 3CEAA?
Every Indian constituent entity of an international group files Part A. Part B is added only when group consolidated revenue is above ₹500 crore and the entity's international transactions are above ₹50 crore, or its intangible property transactions are above ₹10 crore.
What is the due date for the master file for FY 2025-26?
Form 3CEAA is due by the return due date under section 139(1), which is 30 November 2026 for transfer pricing cases.
When is Form 3CEAB required?
When an international group has more than one Indian constituent entity, it can designate one of them to file the master file for all. The designation is intimated in Form 3CEAB at least 30 days before the master file due date.
What is the CbC reporting threshold in India?
Consolidated group revenue of ₹6,400 crore or more in the preceding accounting year.
Does an Indian subsidiary of a foreign group file the CbC report?
Usually not. It files Form 3CEAC to tell the department which entity reports for the group. It files Form 3CEAD itself only in specific cases, such as when the parent's country does not exchange CbC reports with India.
What are the new form numbers from tax year 2026-27?
Form 3CEAA becomes Form 56, 3CEAB becomes 57, 3CEAC becomes 58, 3CEAD becomes 59 and 3CEAE becomes 60, under the Income-tax Rules, 2026.
What is the penalty for not filing the master file?
₹5,00,000 under section 271AA(2) of the 1961 Act.
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Read guide→Official references
The statutory sources behind this page. We keep our guidance aligned to them — verify anything time-sensitive directly.
- Income Tax DepartmentReturns, forms, rates and e-filing utilities
- TRACESTDS certificates and justification reports
- Ministry of Corporate AffairsCompanies Act filings, forms and fee schedules
Facts on this page are checked against these sources; the date of the last check is shown at the top of the page. It is general guidance, not advice on your specific facts. How we write and check our guides.