Country-by-Country (CbC) Reporting
Country-by-Country reporting and notifications for multinational groups — Form 3CEAC, 3CEAD and master file Form 3CEAA.
- Estimate Cost
- ₹50,000 – ₹3,00,000
- Typical duration
- 21 days
Service overview
- Country-by-Country (CbC) reporting requires large multinational groups to report revenue, profit, tax paid, employees and activities for each jurisdiction where they operate
- With the Master File and Local File, it forms the three-tier transfer pricing documentation under OECD BEPS Action 13, which India has adopted
Who needs it? / When is it needed?
- Indian parent entities of multinational groups with consolidated revenue above the threshold (currently Rs 6,400 crore for CbCR).
- Indian subsidiaries and branches of foreign groups that must file notifications or a local CbC report.
- Groups that meet the Master File thresholds.
What to expect from the WCP Professionals
- Applicability analysis and identification of the reporting entity.
- Preparation and filing of CbCR notifications and intimations.
- Collection and reconciliation of jurisdiction-wise data.
- Preparation of the CbC report in prescribed XML format.
- Master File preparation and filing, plus a risk review of the data reported
Key deliverables
- Applicability memo.
- Filed notifications and intimations.
- CbC report and Master File.
- Data reconciliation and risk-flag summary.
Standard turnaround time
- Applicability review: 1 week.
- Data collection and report preparation: 4–8 weeks.
- CbC report due within 12 months of the end of the reporting year; Master File generally due by 30 November.
Government fees, timelines & key outcomes
- No government filing fee.
- Significant daily penalties apply for non-filing or inaccurate reporting.
- Key outcome: timely, consistent global reporting with lower audit risk.
- Income-tax form and section references are under the Income-tax Act, 1961; for periods from 1 April 2026 WCP professionals use the corresponding provisions and forms of the Income-tax Act, 2025.
Forms & filings involved
- Form 3CEAA (Master File).
- Form 3CEAB (intimation of designated entity).
- Form 3CEAC (notification by constituent entity).
- Form 3CEAD (CbC report).
- Form 3CEAE (intimation by alternate reporting entity).
Documents required
- Group structure chart and consolidated financial statements.
- Entity-wise financial and tax data for each jurisdiction.
- Transfer pricing policies.
- Details of the parent and alternate reporting entities.
What we need from you
- Coordination with group finance teams across countries.
- Timely sharing of audited data.
- Sign-off on final reports.
Important conditions
- Data must be consistent with financial statements and the Local File.
- CbC data is shared between tax authorities under exchange agreements.
- Thresholds and forms may change with amendments.
Additional information
- Use CbC data to review your BEPS and Pillar Two exposure.
- Related services: Transfer Pricing Advisory & Documentation, OECD BEPS Compliance & Reporting.
The estimated cost covers indicative professional fees only. Government fees, stamp duty and taxes are payable at actuals.
How it works
- 1. Raise a service enquiry describing your requirement.
- 2. A Relationship Manager reviews it and opens it for bidding.
- 3. Pay into escrow and assign the professional you select.
- 4. Track progress to completion, then accept and release payment.
Frequently asked questions
Who must file a CbC report in India?
Indian parents of international groups with consolidated revenue of ₹6,400 crore or more, and in some cases Indian constituent entities of foreign groups.
What is Form 3CEAC?
The notification by an Indian constituent entity identifying the group entity that will file the CbC report.
When is the CbC report due?
Within 12 months from the end of the group's reporting accounting year.
What does the CbC report contain?
Revenue, profit, tax paid and accrued, capital, employees and assets for each country where the group operates.