Master File & CbCR Compliance
Group-level transfer pricing filings are consistency tests administered globally. Indian authorities read your Master File and Country-by-Country Report alongside the Local File and Form 3CEB, hunting for the contradictions that multinationals generate innocently: value-chain descriptions that credit India with more than the local file admits, profit allocations that sit awkwardly against headcount and assets, and intangibles narratives that undermine royalty deductions being claimed in Mumbai. Every inconsistency is a question, and every question extends the audit.
We prepare and localise these filings so the group's global story and India's local story are the same story. Master Files are reviewed against Indian positions before filing; CbCR data is analysed the way a risk-assessment algorithm will analyse it — flagging the jurisdictional patterns most likely to invite scrutiny; and India-specific filing obligations, thresholds, and deadlines are managed so a purely procedural lapse never invites substantive attention.
What this covers
- Master File preparation or localisation, reconciled against Local File positions before anything is filed.
- CbCR notification and filing compliance, including constituent-entity obligations in India.
- Risk-lens review of CbCR data: the ratios and patterns tax administrations screen for, identified before they do.
- Consistency audits across the full documentation stack — Local File, Master File, CbCR, 3CEB, and financial statements.
- Threshold monitoring as group revenues and Indian transactions grow.
Who needs this
Multinational groups above Master File and CbCR thresholds with Indian constituent entities; group tax teams managing filings across jurisdictions; and companies whose global documentation was written without an Indian reader in mind.
How we deliver
- Group filing review against Indian local positions before submission anywhere.
- India-specific obligations calendared: notifications, filings, and thresholds tracked annually.
- Consistency report flagging the cross-filing contradictions worth fixing this cycle.
Why A2 Consultants
We read your group filings the way an Indian risk algorithm reads them — jurisdiction by jurisdiction, ratio by ratio — and fix the anomalies before they become the reason your file was selected.
Engagement & what to expect
The annual engagement runs against your group filing calendar: Indian obligations mapped, notifications and filings executed inside deadlines, and the group Master File reviewed against Indian local positions before anything is submitted anywhere. The consistency review is the engagement's real value — a report flagging the cross-filing contradictions and CbCR patterns most likely to draw Indian scrutiny, delivered while there is still time to fix or explain them. First-year clients typically add a look-back review of prior filings, since inconsistencies already filed are best discovered by you.
Authorities no longer read your filings one at a time — file the whole stack as one coherent account, or explain the differences in audit.