AS | Ankit Sarawagi|Founder, CFOmatrix·August 2026·9 min read | Transfer Pricing |
Your consultant mentions the Master File, and the first worry is that your small Indian subsidiary now owes a fat group-level document nobody has ever assembled. In almost every startup case, it does not.
The Master File is a transfer pricing document that describes the entire multinational group, not just your Indian entity, and in India it is filed as Form 3CEAA. But it comes in two parts, and the heavy part only switches on above revenue thresholds that most early-stage groups are nowhere near. This guide walks through what the Master File covers, the Part A versus Part B split, the exact thresholds, Form 3CEAB, and the due date, with two worked examples so you can place your own company on the map.
- What it is
- A group-level document on the whole multinational group: structure, business, intangibles, financing, filed as Form 3CEAA (Rule 10DA).
- Part A
- Basic details. Applies to every constituent entity of an international group, with no threshold.
- Part B
- The detailed file. Applies only if group revenue > ₹500 crore AND international transactions > ₹50 crore (or intangibles > ₹10 crore).
- Form 3CEAB
- Intimation designating one Indian entity to file, where a group has several Indian entities.
- Due date
- Form 3CEAA by 30 November; Form 3CEAB at least 30 days earlier.
1 What the Master File actually is
The Master File is one of three transfer pricing documents that flow from the OECD’s BEPS Action 13 and are built into Indian law. Think of them as a set of nested lenses:
- The Local File (your TP study under Rule 10D) zooms in on your Indian entity’s related-party transactions.
- The Master File (Form 3CEAA) zooms out to the whole group: its blueprint.
- The Country-by-Country Report (CbCR, Form 3CEAD) is the group’s tax and profit map across every country it operates in.
So the Master File is not about your India numbers. It is a group-level narrative that lets a tax officer understand where your Indian entity sits inside the larger machine. It typically covers the group’s legal and ownership structure, a description of the business and value chain, its important intangibles and who owns them, its intra-group financing arrangements, and the group’s consolidated financial and tax position.
2 Part A versus Part B: the split that matters
This is the single point that decides how much work the Master File is for you. Form 3CEAA has two parts, and they have completely different triggers.
| Part A | Part B | |
|---|---|---|
| What it is | Basic details: the group, the constituent entities in India, and their addresses | The full Master File: structure, business, intangibles, financing, financials |
| Who files it | Every constituent entity of an international group | Only entities that cross both thresholds below |
| Threshold | None | Group revenue and transaction tests (see section 3) |
| Effort | A short intimation-style form | A substantial group document to assemble |
The key relief for founders: Part A applies to every constituent entity of an international group, but it is a light, details-only filing. The heavy lifting sits entirely in Part B, and Part B has a high floor. Cross the floor and you file both parts; stay below it and you file Part A alone (and only if you are part of an international group that prepares consolidated accounts).
3 The Part B thresholds (the numbers that decide it)
The detailed Master File in Part B applies for an accounting year only if both of these are true:
| Test | Threshold |
|---|---|
| Test 1: Group revenue (always required) | Consolidated group revenue exceeds ₹500 crore in the accounting year |
| Test 2: Transactions (either limb) | Aggregate international transactions exceed ₹50 crore, OR international transactions in intangible property exceed ₹10 crore |
Both tests have to be met. If consolidated group revenue is ₹500 crore or below, Part B does not apply at all, whatever your transaction values. If the group is large but your Indian entity’s international transactions are small (below ₹50 crore, and intangibles below ₹10 crore), Part B still does not apply to you.
4 Two worked examples: where do you land?
Brewly is an Indian SaaS startup running a captive dev-centre for its parent, Brewly Inc, incorporated in Delaware. The group files consolidated accounts with total revenue of about ₹90 crore. Brewly India charges its parent cost-plus fees of roughly ₹22 crore for the year, with no separate intangibles transaction. Test 1 fails immediately: group revenue of ₹90 crore is far below ₹500 crore. So Brewly files only Part A of Form 3CEAA (basic details as a constituent entity), and skips Part B entirely. Its real transfer pricing effort stays in Form 3CEB and its Rule 10D Local File.
Brewly at scale. Fast forward three years: Brewly Inc has raised large rounds, the consolidated group now reports revenue of ₹640 crore, and Brewly India’s cost-plus service charges to group entities have grown to ₹61 crore for the year. Now both tests are met: group revenue > ₹500 crore (Test 1), and international transactions of ₹61 crore > ₹50 crore (Test 2). Brewly India must file both Part A and Part B of Form 3CEAA. The parent’s group finance team assembles the Part B narrative (structure, value chain, intangibles, financing), and Brewly India files it in India by the due date.
5 Form 3CEAB: designating one Indian filer
Some international groups have more than one constituent entity resident in India (say an operating company and a separate R&D entity). The law does not want each of them filing an identical Master File. So the group can designate one Indian entity to file Form 3CEAA on behalf of all of them, and it tells the tax authority which one in Form 3CEAB.
Form 3CEAB is a short intimation, not a document. It simply names the designated filer. It must be filed at least 30 days before the due date for filing Form 3CEAA. If you are the only Indian constituent entity of your group, you do not need Form 3CEAB at all; you just file Form 3CEAA yourself.
6 The filing sequence and due dates
If Part B applies to your group and you have several Indian entities, the moving parts run in this order.
In short: Form 3CEAB by around 31 October (30 days before), and Form 3CEAA by 30 November. Keep the underlying documents ready to produce if the officer asks during assessment.
7 Your Master File checklist
- Confirm whether you are a constituent entity of an international group that prepares consolidated financial statements. If yes, Part A of Form 3CEAA is on your radar.
- Test the two Part B thresholds: consolidated group revenue over ₹500 crore AND international transactions over ₹50 crore (or intangibles over ₹10 crore).
- If both are met, plan for Part A plus Part B; if not, plan for Part A only.
- If your group has more than one Indian entity and Part B applies, agree the designated filer and file Form 3CEAB at least 30 days before the Form 3CEAA due date.
- File Form 3CEAA electronically by 30 November of the assessment year.
- Keep a living note of group structure, intangibles and financing so Part B is not written under deadline pressure.
- Do not treat the Master File as a substitute for Form 3CEB or your Rule 10D Local File; all three are separate obligations.
Not sure which transfer pricing filings apply to you?
Use our free Transfer Pricing Applicability Checker: tell it about your foreign parent or subsidiary and what flows between you, and see exactly which of Form 3CEB, the Local File, the Master File and CbCR you owe, and at what thresholds.
Check my transfer pricing8 FAQs
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Related guides & tools
Transfer pricing for startups: the full India guide →
Country-by-Country Report (CbCR, Form 3CEAD) in India →
Transfer pricing documentation and the Local File (Rule 10D) →
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 due dates can change and depend on your specific group facts. Confirm your obligations with a qualified professional before acting.