Form No. 56 – Master File

Purpose:

Relevant rule for Form No. 56 is Rule 123 of the Income-tax Rules, 2026. Form No. 56 (Master File) is an income-tax reporting document with the purpose to enhance tax transparency and compliance with transfer pricing regulations for multinational enterprises (MNEs). The form is mandated under section 171 of the Income-tax Act, 2025 read with Rule 123 of the Income-tax Rules, 2026.

Who Should File:

Every person, being a constituent entity of an international group shall file Form No. 56 if the following conditions are satisfied:

• The consolidated group revenue of the international group, as per its consolidated financial statements, exceeds INR 500 crore for the accounting year, and
• The aggregate value of international transactions as per the books of account exceeds INR 50 crore during the accounting year, or aggregate value of international transactions involving intangible property as per the books of account exceeds INR 10 crore.

However, as per Rule 123(3), the constituent entity shall furnish Part A of Form No. 56 even if the conditions prescribed in Rule 123(1) i.e. the aforesaid conditions are not satisfied.

Frequency & Due Dates:

The due date for filing Form No. 56 is the same as the due date for filing the return of income as specified under Section 263(1)(c) of the Income-tax Act, 2025.

Structure of Form No. 56:

Part A: Particulars of the person

Part A requires basic identification details such as name, address, PAN, email id and contact number of the constituent entity.

Part B: Other information

Part B requires Accounting Year for which the information and document are being submitted, details of the international group of which the assessee is a constituent entity, details of all the constituent entities of the international group operating in India, details of all the constituent entities of the international group, and other details to be provided as separate enclosure as per Note 4 to the form which include Annexures A-1 to A-11.

What are the documents required to file Form No. 56?

The following information/document in relation to the internation group may be required for filing Form No. 56:

• Name and address of the international group of which the assessee is a constituent entity
• List of all constituent entities of the international group along with their addresses, and PANs of those constituent entities operating in India
• Chart depicting the legal status of the constituent entity and ownership structure of the entire international group
• Written description of the business of the international group during the accounting year in accordance with rule 123(1)(C) containing the following, namely: —

(i) the nature of the business or businesses;

(ii) the important drivers of profits of such business or businesses;

(iii) a description of the supply chain for the five largest products or services of the international group in terms of revenue and any other products including services amounting to more than five per cent of the consolidated group revenue;

(iv) a list and brief description of important service arrangements made among members of the international group, other than those for research and development services;

(v) a description of the capabilities of the main service providers within the international group;

(vi) the transfer pricing policies for allocating service costs and determining prices to be paid for intra-group services;

(vii) a list and description of the major geographical markets for the products and services offered by the international group;

(viii) the functions, assets and risks analysis of the constituent entities of the international group that contribute at least ten per cent of the revenues or assets or profits of such group; and

(ix) a description of the important business restructuring transactions, acquisitions and divestments

• Description of the overall strategy of the international group for the development, ownership and exploitation of intangible property, including location of principal research and development facilities and their management
• List and brief description of important agreements among members of the international group related to intangible property, including cost contribution arrangements, principal research service agreements and license agreements
• Description of the transfer pricing policies of the international group related to research and development and intangible property
• Description of important transfers of interest in intangible property, if any, among entities of the international group, including the names and addresses of the selling and buying entities and the compensation paid for such transfers
• Detailed description of the financing arrangements of the international group, including the names and addresses of the top ten unrelated lenders
• List of group entities that provide central financing functions, including their addresses of operation and of effective management
• Detailed description of the transfer pricing policies of the international group related to financing arrangements among group entities
• A copy of the annual consolidated financial statement of the international group
• A list and brief description of the existing unilateral advance pricing agreements and other tax rulings in respect of the international group for allocation of income among countries

What is the process flow of filing Form No. 56?

Form No. 56 is an e-Form, and following are the steps to file it online:

• Login to the e-filing portal
• On the dashboard, click ‘e-File’ > ‘Income Tax forms’ > ‘File Income Tax Forms’
• Scroll down to select Form No. 56
• Alternatively, enter Form No. 56 in the search box. Click on ‘File now’ button to proceed
• After checking the documents required for filing the form click on 'Let's Get Started'
• Fill all the necessary details, attach the necessary documents and click on ‘Preview’
• After reviewing all the information, ‘Proceed’ to e-Verify'
• After verification Click on 'Yes' to submit the Form.