Master File and CbCR: Keystones of Indian Transfer Pricing Compliance (AY 2024-25)
In 2016, India became an active member of the Base Erosion and Profit Shifting ("BEPS") initiative by the Organization for Economic Co-operation and Development (OECD). As part of this initiative, India adopted the three-tier transfer pricing documentation structure prescribed by the OECD under BEPS action 13, namely – (a) Master File (b) local documentation file, and (c) CbCR (country by country reporting).
The Master File outlines a multinational group's global operations and transfer pricing policies giving an overall understanding of the group’s business, intangibles, financing, markets, services and products offered, etc., while CbCR provides a high-level overview of income, profit, taxes, and economic activity across jurisdictions. Both reports are required for MNEs to meet certain revenue thresholds as listed in the later part of this document.
a) Master File (Form 3CEAA)
b) Local File (Transfer Pricing study)
c) Country by Country Report (CbCR)
Navigating the intricate landscape of Indian transfer pricing can be challenging for multinational businesses. BCL India specializes in providing tailored transfer pricing solutions. Whether you're struggling with documentation requirements, ensuring adherence to the Indian TP regulations, or facing potential penalties, we're here to assist. Let's work together to develop effective strategies that align with your business objectives and mitigate tax liabilities.
Feel free to reach out!???????????????