Master File (Rule 10DA): Definition, Triggers and Contents

Definition

The Master File is the group-level transfer pricing documentation: the documentation that describes the multinational group as a whole, under Rule 10DA of the Income-tax Rules (the BEPS Action 13 master-file standard, adopted into Indian law). Where the Local File is the entity’s defence, the Master File is the group’s story — and the document an examination reads before it reads the entity’s file, because the group story frames what the entity’s file has to explain.

Trigger. The obligation attaches to groups with consolidated revenue of ₹1,000 crore or more — the same threshold as the CbCR. It is prepared at group level (typically by the ultimate parent, or a designated member where the UPE’s jurisdiction does not require it) and must be available to the entity that needs it in an Indian examination.

Contents. The four standard areas:

1. Group structure — all group members, ownership, jurisdictions.
2. Nature of the business — the group’s businesses, by segment.
3. Intangibles — the intangibles owned or licensed, their ownership and the strategy for them.
4. Financial and tax positions — the group’s consolidated financials and its tax positions.

Why consistency with the Local File is the audit trap

The Master File and each Local File are built from the same facts, so they must agree: the group structure in the Master File is the structure each Local File describes for itself; the intangibles the Master File says the group owns are the intangibles the Local Files allocate (or disclaim); the financials are the same numbers the returns file. A mismatch between the two is the pattern a scrutiny team looks for — it means one of the two documents was not drawn from the actual records. The documentation pillar guide covers the cross-document consistency checks in full.

Example

A group with ₹1,800 cr consolidated revenue maintains its Master File at the ultimate parent: the ownership tree (nine members, five jurisdictions), the business segments, the intangibles register (the core software, owned by the IP-holding member, licensed group-wide), and the consolidated financials. The Indian operating entity’s Local File must tell the same story at entity level: it uses the software under licence, it does not own it — and if the Local File’s FAR says otherwise, that is the finding before the pricing is even reached.

See also

• Local File
• CbCR
• The documentation pillar guide

FAQ

Who prepares the Master File for an Indian group? The ultimate parent in its jurisdiction, where that jurisdiction requires it; otherwise a designated group member in a jurisdiction that does (often the Indian entity in an Indian-UPE structure). The requirement is availability to the Indian entity, not location.

Is the Master File filed in India? It is maintained and available, not filed as a standalone return — the filed group-level artefact in the Indian set is the CbCR (Rule 10DB), where the group is in scope. The Master File is produced on demand, and its absence surfaces in the same examination as the Local File fight.