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<h1>Master file reporting requires multinational groups to file comprehensive group and transfer pricing documentation under section 92D.</h1> Report obligation under sub section (4) of section 92D requires submission of Master File (Form 3CEAA) containing: identification of the assessee and international group; list of constituent entities and addresses; legal status and ownership chart; written business description covering nature of business, profit drivers, supply chains, inter group services and transfer pricing policies; functions assets risks analysis for material contributors; intangible property strategy and ownership; inter company financing arrangements and policies; consolidated financial statements; and a list of unilateral APAs and tax rulings, with a verification declaration.
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