Master File: Content, Triggers and Best Practices (Rule 10DA + OECD)

The Master File is the group-level tier of transfer pricing documentation: the description of the multinational group as a whole — its structure, its businesses, its intangibles, its TP policies and its financial and tax position. In India it is prescribed by Rule 10DA of the Income-tax Rules (the BEPS Action 13 master-file standard adopted into Indian law); in the OECD framework it is the Action 13 master file for groups above the €750 million revenue threshold. Where the Local File answers “how did this entity price its transactions?”, the Master File answers “how does this group work, and what is its pricing architecture?”

The trigger: when the Master File is required

Regime	Threshold	Who maintains it
India (Rule 10DA)	Aggregate revenue of the MNE group in the immediately preceding financial year of ₹1,000 cr or more	The relevant entity of the group — the group’s head office where it is in India; where the head office is outside India, the topmost Indian constituent entity of the group
OECD (BEPS Action 13)	Consolidated group revenue of €750 million or more (the base-year test)	The ultimate parent entity (or the surrogate parent entity where the ultimate parent’s jurisdiction does not require the master file)

The threshold test is on the group’s aggregate revenue, not the Indian entity’s — a small Indian entity inside a large group can be the entity that must maintain the file, and a large Indian entity inside a smaller group can have no master-file obligation at all (the Local File and CbCR questions are answered on their own thresholds).

The Indian Master File, like the OECD’s, is a maintain-and-produce document: it must exist, contemporaneously, and be produced when the authority requests it — it is not filed proactively the way the CbCR return is.

The content: the Rule 10DA blocks

Rule 10DA prescribes the master file’s content, and the blocks map closely to the OECD standard:

Block	The content	The examination use
Description of the MNE group’s business	The segmental breakdown — business activities, revenue and profit by segment — of the group as a whole	The segment data the Local Files reference; the basis of the group’s functional picture
Structure of the MNE group	The organizational chart, the constituent entities by jurisdiction, the location of the head office	The map of who is in scope for the group’s documentation, and the entity relationships the transactions run between
Description of the group’s intangibles	The group’s intangibles — what they are, who owns them, how they are valued and allocated	The intangibles attribution across the group; the reference for the royalty and split analyses in the Local Files
Description of the group’s TP policies	The nature of the group’s controlled transactions, the methods used for pricing (the master-level statement of method, PLI and approach)	The consistency standard: every Local File’s method claim is checked against the group policy
Financial and tax information	The ownership of and contribution to cost sharing arrangements; the tax adjustments made with an analysis; the list of APAs; the list of MAP agreements	The group’s adjustment history and its dispute posture — the file that shows the group’s own record of where its pricing has been challenged

The practical reading of the content blocks: the Master File is the group’s TP narrative in legal form — the structure, the intangibles, the methods — and every entity-level Local File is an application of that narrative. A Local File that prices a transaction in a way the group’s master-level policy does not support has a contradiction built into the documentation set.

The India–OECD deltas

Dimension	India (Rule 10DA)	OECD (Action 13)
Threshold	₹1,000 cr aggregate group revenue (preceding FY)	€750 mn consolidated group revenue (base year)
Maintainer	The relevant entity (head office in India, or topmost Indian entity)	The ultimate (or surrogate) parent entity
CCA/CSA emphasis	Explicit block for cost sharing / cost contribution arrangements and the tax adjustments	The financial and tax information block, incl. CSAs and jurisdictional TP policies
Interaction with CbCR	The Master File and the CbCR (Form 3CEB) are separate documents with related data — consistency between them is the file’s discipline	Same — the master file’s segment data and the CbCR’s country data must reconcile
Production	On request (maintain-and-produce)	As per the jurisdiction’s implementation (most: maintain, produce on request or file)

The deltas are minor in substance — the content is the Action 13 content — and the file that is written once, well, serves both regimes. The threshold difference (₹1,000 cr vs €750 mn) means the two regimes can be triggered on different groups in edge cases; the group that is in scope under one and not the other writes the master file for the regime that requires it and notes the other’s non-applicability.

Best practices

1. The Master File is the group’s reference document, not a filing. Write it as the document the entity-level files cite — the Local File’s method statement, the intangibles description, the structure — so the citation is true. A Master File no Local File references is a document; a Master File the Local Files build on is a system.
2. The segment data is the load-bearing block. The segmental revenue and profit breakdown is the data the CbCR, the Local Files and the group’s management reporting all draw from — one source, the management accounts, mapped identically into all three. A Master File segment table that does not reconcile to the CbCR country rows is the inconsistency the risk assessment is designed to find.
3. The TP policy block is the method register. The group’s statement of methods — per transaction type, per entity class (the distributor’s OP/Sales, the service centre’s OP/OC, the R&D entity’s cost plus, the safe harbour elections) — is the standard every Local File is checked against, and the place where a method change (year to year, entity to entity) is documented as a decision rather than discovered as drift.
4. The intangibles block is the ownership map. The group’s intangibles, the owners, the allocations, the valuations — the reference for every royalty and split analysis in the group. Where the intangibles block and a Local File’s DEMPE record disagree, the examination has its question.
5. The update is annual and event-driven. The file is refreshed with the group’s annual cycle (the structure change, the new entity, the new intangible, the new transaction type) and on events (the restructuring, the new CSA, the first tax adjustment). The version history is part of the file — the Master File for year N is not silently rewritten for year N+1.
6. The consistency check is a named step. Before the Local Files are finalized, the named reconciliation: the Master File’s structure vs the Local Files’ entity descriptions, the intangibles block vs the DEMPE records, the method register vs the declared methods, the segment data vs the CbCR. The reconciliation is documented — it is the three-tier consistency proof, and it is the documentation pillar guide’s core discipline applied at the group level.

See also

• The documentation pillar guide
• Local File — Rule 10D
• CbCR — thresholds and filing
• Master File (Rule 10DA) — glossary