The master file is the cornerstone of transfer pricing documentation for multinational enterprises. Rule 123 of the Income Tax Rules, 2026 specifies the information and documents that must be maintained. This comprehensive checklist ensures no critical element is missed.
Organisational Structure Documentation
Entities and Ownership
- List of all entities of the international group along with their addresses
- Chart depicting the legal status of the constituent entity
- Ownership structure of the entire international group
- Details of shares or other ownership interest held therein by other enterprises
Business Description Documentation
Business Overview
- Description of the nature of the business or businesses
- Important drivers of profits of such business or businesses
Supply Chain
- Description of the supply chain for the five largest products or services in terms of revenue
- Any other products including services amounting to more than 5% of consolidated group revenue
Service Arrangements
- List and brief description of important service arrangements made among members of the international group
- Description of the capabilities of the main service providers
Transfer Pricing Policies
- Details about transfer pricing policies for allocating service costs
- Determination of prices to be paid for intra-group services
Geographical Markets
- List and description of the major geographical markets for products and services
Functional Analysis
- Description of functions performed, assets employed, and risks assumed by constituent entities contributing at least 10% of revenues, assets, or profits
Business Restructuring
- Description of important business restructuring transactions, acquisitions, and divestments
Intangible Property Documentation
Strategy and Management
- Description of the overall strategy for development, ownership, and exploitation of intangible property
- Location of principal research and development facilities and their management
Entities and Ownership
- List of all entities engaged in development and management of intangible property
- List of all important intangible property or groups of intangible property
- Names and addresses of group entities that legally own such intangible property
Agreements
- List and brief description of important agreements related to intangible property
- Cost contribution arrangements
- Principal research service agreements
- License agreements
Transfer Pricing Policies
- Detailed description of transfer pricing policies related to research and development
- Transfer pricing policies related to intangible property
Transfers
- Description of important transfers of interest in intangible property
- Name and address of selling and buying entities
- Compensation paid for such transfers
Financing Arrangements Documentation
Overview
- Detailed description of the financing arrangements of the international group
- Names and addresses of the top ten unrelated lenders
Central Financing Functions
- List of group entities that provide central financing functions
- Place of operation and of effective management
Transfer Pricing Policies
- Detailed description of transfer pricing policies related to financing arrangements among group entities
Financial Information Documentation
Financial Statements
- Copy of the annual consolidated financial statement of the international group
Tax Rulings
- List and brief description of existing unilateral advance pricing agreements
- Other tax rulings in respect of the international group for allocation of income among countries
Compliance Requirements
Filing
- Form No. 56 furnished on or before the due date for furnishing the return of income
- Part A of Form No. 56 furnished even if conditions are not satisfied
Designated Entity
- If multiple entities, Form No. 56 furnished by designated entity
- Form No. 57 conveyed to the Joint Director
Retention
- Information and documents kept for nine years from the end of the relevant tax year
Expert Legal Guidance
Ensuring complete master file documentation is essential for transfer pricing compliance. Anuj Desai & Associates provides expert advisory services on transfer pricing documentation, helping taxpayers maintain compliant master files.
Reference Guidemaster file content checklistmaster file documentation checklistmaster file international grouptransfer pricing master file contentmaster file required documentsmaster file checklist Indiamaster file content requirementsmaster file documentation listmaster file contents guidemaster file compliance checklistmaster file documentation requirementsmaster file contents international groupmaster file transfer pricing checklistmaster file content guidemaster file documentation Indiamaster file contents rule 123master file compliance guidemaster file documentation practicalmaster file contents explainedmaster file checklist for MNEs