AS | Ankit Sarawagi|Founder, CFOmatrix·August 2026·8 min read | Transfer Pricing |
Country by country reporting sounds like a filing every startup with a foreign parent should worry about. For almost all of you, it is the one transfer pricing form you will never touch.
CbCR is the top tier of the three-tier documentation that came out of BEPS Action 13, and it is built for the world’s largest multinational groups. In India it is filed on Form 3CEAD, and it only switches on when a group’s consolidated revenue crosses ₹6,400 crore. This guide explains what the report actually contains, who files it, the ₹6,400 crore threshold and the due dates, and exactly when a fast-scaling group might finally cross into it.
- What it is
- A group-level report of revenue, profit, tax, capital, employees and assets, split per country (BEPS Action 13).
- India form
- Form 3CEAD is the report; Form 3CEAC is the intimation naming who will file it.
- Threshold
- Consolidated group revenue above ₹6,400 crore in the preceding accounting year (mirrors EUR 750 million).
- Who files
- The parent entity in its home country, or a designated / alternate reporting entity.
- Due date
- 12 months from the end of the reporting accounting year.
1 What country by country reporting actually is
Transfer pricing documentation has three tiers, and country by country reporting is the top one. The Local File (your TP study under Rule 10D) is about your entity’s transactions. The Master File (Form 3CEAA) describes the group’s global business. The CbCR is a single spreadsheet-style report that lays the group’s economics out country by country, so a tax authority can see at a glance where revenue, profit, tax and people actually sit.
The idea behind BEPS Action 13 is simple: if a group books most of its profit in a low-tax jurisdiction where it has three employees and no real activity, that shows up starkly when every country is lined up in one table. CbCR is a risk-assessment tool for tax administrations, not a basis for a direct adjustment on its own.
2 The ₹6,400 crore threshold, and why startups are outside it
CbCR applies only where the international group’s consolidated revenue for the preceding accounting year is more than ₹6,400 crore. That figure is the Indian rupee equivalent of the OECD’s EUR 750 million standard, so it is deliberately set at the level of genuinely large multinationals.
Put that next to the other transfer pricing thresholds and the gap is obvious. Form 3CEB is triggered by a single rupee of international transaction with an associated enterprise. The TP study kicks in above ₹1 crore. The Master File needs group revenue over ₹500 crore. CbCR needs ₹6,400 crore, which is more than twelve times the Master File figure.
| Obligation | What it looks at | Trigger |
|---|---|---|
| Form 3CEB (accountant’s report) | Your entity’s transactions with an AE | Any international transaction (no minimum) |
| TP study / Local File (Rule 10D) | Your entity’s transactions | Above ₹1 crore in the year |
| Master File (Form 3CEAA) | The group’s global structure | Group revenue over ₹500 crore and international transactions over ₹50 crore |
| CbCR (Form 3CEAD) | The group’s economics, per country | Consolidated group revenue above ₹6,400 crore |
3 Who files, and the Form 3CEAC intimation
The default rule is that the parent entity of the group files the CbCR in the country where it is resident, and that country then shares it with India under an exchange agreement. So if Brewly’s US parent files a CbCR with the IRS, the Indian tax authority receives it automatically; the Indian subsidiary does not re-file the report.
What the Indian constituent entity does have to do, even when the parent files abroad, is submit Form 3CEAC. This is an intimation that names the entity which will actually file the CbCR (the parent, or a designated alternate reporting entity) and its country of residence. It is a short notification, but it is a separate obligation with its own deadline.
An Indian entity only has to file the full Form 3CEAD itself in narrow fallback cases, for example where the parent’s country has no exchange arrangement with India, or systematically fails to share reports. Where several Indian constituents belong to the same group, they can designate one of them to file, using Form 3CEAE.
4 What is inside the report: the data points
The heart of Form 3CEAD is a table with one row per tax jurisdiction the group operates in. For each country, the group reports the following.
| Data point | What it captures |
|---|---|
| Revenues: unrelated party | Revenue earned in that country from third parties |
| Revenues: related party | Revenue from other group entities (intercompany) |
| Revenues: total | The two above, combined |
| Profit / loss before income tax | Pre-tax result booked in that country |
| Income tax paid (cash basis) | Tax actually paid during the year |
| Income tax accrued (current year) | Tax charge accrued for the current year |
| Stated capital | Declared capital of the constituent entities there |
| Accumulated earnings | Retained earnings sitting in that country |
| Number of employees | Headcount in the jurisdiction |
| Tangible assets (other than cash) | Physical assets, excluding cash and cash equivalents |
Alongside this table, the report lists every constituent entity by jurisdiction with its main business activities (manufacturing, R&D, holding, sales, services and so on), plus a free-text section for any additional context. The point of pairing profit and tax with employees and real assets is to show whether profit is sitting where the actual activity is.
5 A worked example: when a group actually crosses the line
The threshold is high, but a fast-scaling group can reach it. Here is how the maths works, and why the trigger is about the whole group, not your slice of it.
Brewly is an Indian captive dev-centre for a US parent. The Indian entity bills the parent on cost-plus and books roughly ₹40 crore of revenue. Nowhere near any CbCR threshold on its own. But the US parent has grown fast: its consolidated group revenue for the preceding year, across the US, India, Singapore and the UK, is ₹7,100 crore. Because that consolidated figure is above ₹6,400 crore, the whole group is now in CbCR, and Brewly’s tiny ₹40 crore Indian entity picks up a Form 3CEAC intimation duty even though the US parent files the actual Form 3CEAD with the IRS.
Compare a group still below the line. Kaveri‘s international group had consolidated revenue of ₹480 crore last year. It is below the CbCR threshold (₹6,400 crore) and even below the Master File threshold (₹500 crore). Kaveri files Form 3CEB and keeps a TP study because its international transactions cross ₹1 crore, but it files no Master File and no CbCR. As the group scales, the Master File duty at ₹500 crore will arrive first, and CbCR only much later, if ever.
6 A quick checklist for a group approaching the threshold
- Track the international group’s consolidated revenue, not just your Indian turnover, against the ₹6,400 crore line each year.
- Confirm whether the Master File threshold (₹500 crore group revenue with over ₹50 crore of international transactions) has been crossed first, as it almost always will be.
- Identify the reporting entity: the parent, or a designated alternate reporting entity, and its country of residence.
- If your Indian entity is a constituent of a group above the threshold, file Form 3CEAC at least two months before the CbCR due date.
- Where multiple Indian constituents exist, designate one to file using Form 3CEAE.
- Ensure the parent files Form 3CEAD within 12 months of the reporting year end, and that an exchange arrangement with India exists.
- Build the ten data points from consolidated group data, reconciled to the group accounts, well before the deadline.
Not sure which transfer pricing forms apply to you?
Most startups owe Form 3CEB and a TP study long before Master File or CbCR are ever in scope. Use our free checker: enter your foreign parent or subsidiary and what flows between you, and see exactly which filings you owe now.
Check my transfer pricing7 FAQs
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Related guides & tools
Master File (Form 3CEAA): the tier below CbCR →
Transfer pricing documentation and the TP study (Rule 10D) →
Transfer pricing for startups: the full India guide →
Transfer Pricing Applicability Checker (free tool) →
AS | Founder, CFOmatrix | Finance Strategy & Compliance CFOmatrix helps Indian startups build finance, tax and compliance functions that stand up to investor due diligence, from process and controls to the filings and the numbers behind them. |
Disclaimer: This article is general information as of August 2026 and is not tax or legal advice. Transfer pricing thresholds, forms and section numbers can change with CBDT notifications and the transition to the Income-tax Act, 2025. Confirm your specific obligations with a qualified professional before acting.