Transfer Pricing Documentation Local File, Master File, CbCR — the three-tier rulebook.

India has adopted the OECD's three-tier transfer pricing documentation framework. Every taxpayer with related-party transactions maintains a Local File under Rule 10D; large multinational groups additionally file a Master File in Form 3CEAA under Rule 10DA; and ultimate parent entities of groups crossing the consolidated revenue threshold file Country-by-Country Reports in Form 3CEAD.

Each tier has its own scope and audience. The Local File explains the Indian entity's transactions; the Master File gives the global organisational, financial, and tax picture of the group; the CbCR provides jurisdiction-by-jurisdiction revenue, profit, tax, and employee data accessible to tax authorities worldwide through information exchange.

We prepare and file all three tiers — Local File for the year-end TP study, Form 3CEAA for the Master File, and Form 3CEAD for CbCR — with consistency across the documents and full reconciliation with consolidated financials, Form 3CEB, and the corporate income tax return.