Global / Transfer Pricing Documentation

Multinational groups must maintain a three-tier set of transfer-pricing documentation under the BEPS Action 13 standard, adopted in India — the master file (group-level), the local file (entity-level), and the country-by-country report (CbCR) for large groups.

The firm prepares and files this documentation consistently across the group, so the group's transfer-pricing position is coherent and defensible.

Global documentation covers the three tiers, including:

• The master file (Form 3CEAA) — the group's global picture
• The local file — the entity's related-party transactions and analysis
• The country-by-country report (Form 3CEAD) for large groups
• Consistency of the group narrative across jurisdictions
• The intimation and filing formalities (3CEAB / 3CEAC)

1. 01

   Assess thresholds

   Determine which tiers apply to the group and the entity.

2. 02

   Gather & analyse

   Collect the group and entity data and the analysis.

3. 03

   Document

   Prepare the master, local, and CbCR documents consistently.

4. 04

   File

   Complete the filings and intimations within the deadlines.

PBT prepares your group's transfer-pricing documentation to standard.

• The right tiers identified for the group
• Consistent, defensible documentation
• CbCR and master-file filings handled
• Aligned with the local transfer-pricing study
• Scope, deliverables, and fees agreed in writing up front

• Which entities need a master file and CbCR?

  The master file applies above prescribed thresholds; CbCR applies to groups with consolidated revenue above the limit (₹6,400 crore). We confirm what applies.

• How does this relate to the transfer-pricing study?

  The local file builds on the entity's transfer-pricing study; the master file and CbCR add the group view. We keep them consistent.

• How long does it take?

  Preparing the documentation takes a few weeks; we plan it to the filing deadlines.