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Transfer Pricing

July 2026

Master File and CbCR Compliance in India Income-tax Act, 2025 (FY 2026-27)

Master File and Country-by-Country Reporting (CbCR) in India: Key Compliance Requirements under the Income-tax Act, 2025 (Effective from Tax Year 2026-27)

Introduction

India’s transfer pricing framework continues to evolve in line with international tax transparency standards. With the Income-tax Act, 2025 coming into effect from 1 April 2026, replacing the Income-tax Act, 1961, Multinational Enterprise (MNE) groups must now comply with transfer pricing documentation requirements under the new legislative framework.

The Income-tax Act, 2025 simplifies the structure and language of India’s direct tax law while preserving the substantive requirements relating to transfer pricing documentation, including the Master File and Country-by-Country Reporting (CbCR) introduced in line with the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13 recommendations.

Although the law has been reorganized and section references have changed, the compliance objective remains the same—to provide tax authorities with a transparent view of an MNE group’s global operations, value creation and allocation of profits across jurisdictions.

Legislative Framework

From Tax Year 2026-27 onwards, Master File and Country-by-Country Reporting are governed by the Income-tax Act, 2025 and the Income-tax Rules, 2026. One of the most notable procedural changes introduced by the new Act is the replacement of the concepts of Previous Year and Assessment Year with a single Tax Year, simplifying tax administration and compliance.

The substantive documentation requirements for transfer pricing continue to follow the OECD’s three-tier documentation approach:

  • Local File
  • Master File
  • Country-by-Country Report (CbCR)

Accordingly, multinational groups must continue maintaining robust transfer pricing documentation, with compliance obligations now arising under the corresponding provisions of the Income-tax Act, 2025 and the Income-tax Rules, 2026.

Master File Compliance

A constituent entity resident in India is required to furnish a Master File where the prescribed thresholds relating to consolidated group revenue and international transactions are met. The documentation requirements continue to broadly align with the OECD BEPS Action 13 framework.

Where multiple constituent entities of the same international group are resident in India, one designated entity may file the Master File on behalf of all eligible Indian constituent entities.

The prescribed filing forms notified under the Income-tax Rules, 2026 should be used for compliance. Taxpayers should also refer to the CBDT’s updated guidance and forms applicable under the new legislative framework.

Country-by-Country Reporting (CbCR)

The Country-by-Country Reporting framework continues to apply to eligible multinational groups exceeding the prescribed consolidated revenue threshold.

The report provides jurisdiction-wise information relating to:

  • Revenue
  • Profit or loss before tax
  • Income tax paid and accrued
  • Stated capital
  • Accumulated earnings
  • Number of employees
  • Tangible assets
  • Constituent entities and principal business activities

Indian parent entities, alternate reporting entities and constituent entities are required to comply with the applicable notification and reporting requirements within the prescribed timelines under the Income-tax Rules, 2026.

Key Compliance Updates Under the Income-tax Act, 2025

The transition to the new law does not significantly alter the scope of Master File or CbCR reporting. However, taxpayers should note the following important changes:

  • References to the Income-tax Act, 1961 should be updated to the Income-tax Act, 2025.
  • Compliance is now based on the concept of the Tax Year, replacing the earlier Previous Year and Assessment Year terminology.
  • Transfer pricing documentation should refer to the corresponding provisions of the Income-tax Act, 2025 and the Income-tax Rules, 2026.
  • Internal transfer pricing policies, documentation templates and compliance manuals should be updated to reflect the new statutory references.
  • Businesses should ensure that compliance software, ERP systems and reporting checklists are aligned with the revised legal framework before the filing deadlines.

Frequently Asked Questions (FAQ’s)

A: The Income-tax Act, 2025 replaces the Income-tax Act, 1961 with effect from April 1, 2026. While the law simplifies structure and language, it preserves the substantive Master File and CbCR requirements introduced in line with the OECD’s BEPS Action 13 recommendations. 

A: The replacement of the concepts of Previous Year and Assessment Year with a single Tax Year, simplifying tax administration and compliance terminology.

A: The OECD’s three-tier documentation approach continues to apply:

  • Local File
  • Master File
  • Country-by-Country Report (CbCR)

A: No — one designated entity may file the Master File on behalf of all eligible Indian constituent entities of the same international group.

While the Income-tax Act, 2025 introduces a modernized and simplified legislative framework, the core principles governing Master File and Country-by-Country Reporting remain consistent with India’s long-standing commitment to the OECD BEPS Action 13 standards. Multinational enterprise groups should use this transition as an opportunity to review and update their transfer pricing documentation, governance processes and internal compliance systems to ensure seamless compliance under the new law.

Update your TP documentation before the deadline. UJA Global Advisory — reach out now! 

Conclusion

While the Income-tax Act, 2025 introduces a modernized and simplified legislative framework, the core principles governing Master File and Country-by-Country Reporting remain consistent with India’s long-standing commitment to the OECD BEPS Action 13 standards. Multinational enterprise groups should use this transition as an opportunity to review and update their transfer pricing documentation, governance processes and internal compliance systems to ensure seamless compliance under the new law. 

Update your TP documentation before the deadline. UJA Global Advisory — reach out now!