Cost-effective Form 3CEAB — master file intimation in India

Form 3CEAB — who files it, when it is due, what late filing costs, and what we charge to prepare it. India (Income Tax Department). Cost-effective Form 3CEAB with a fixed fee agreed in writing before any work starts. Call the 24-hour helpline on +1 (416) 619-0068, or request a written quote today.

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  • Fixed fee agreed before work starts
  • 18,000+ clients served
  • 24-hour helpline: +1 (416) 619-0068
In 60 words

Form 3CEAB is an information return: The intimation designating which Indian entity of a group will file the master file. Groups with more than one Indian constituent entity.

Do you need this?

Groups with more than one Indian constituent entity.

Read this first; the rest is procedure. A small procedural filing with a real consequence: without the designation, every Indian entity is exposed to the filing default rather than one.

The firm’s founder at his desk in the Delhi office

What form 3ceab India costs here

Form 3CEAB is a short filing, and the fee reflects that: the work is establishing how many Indian constituent entities the group actually has and which of them should be designated, then filing the intimation. Where the group chart is unclear, that identification is the part that takes the time.

Master file & CbCR — fixed-fee price

From $2,500

fixed, quoted before work starts

The group-level documentation and the country-by-country report, prepared so they agree with each other and with every local file in the footprint.
See the full fee page

Transfer pricing — local file — fixed-fee price

From $2,500

fixed, quoted before work starts

The local file for one entity: functional analysis, method selection with the alternatives explained, comparables with the search documented, and the results tested against the range.
See the full fee page

Transfer pricing documentation

From $2,500

fixed, quoted before work starts

Documentation for transactions between related companies: the method, the comparables and the file an authority asks to see.
See the fee schedule

Corporate cross-border filing

From $999

fixed, quoted before work starts

Returns for companies with foreign subsidiaries, foreign income or foreign shareholders, and the schedules each of those triggers.
See the fee schedule

Foreign asset & information reporting

From $349

fixed, quoted before work starts

The reporting obligations that attach to owning something abroad, worked out from your holdings rather than from the tax return alone.
See the fee schedule

Individual tax filing

From $349

fixed, quoted before work starts

Individual returns where salary, investments or property sit outside the country of residence, prepared so relief is claimed once and in the right place.
See the fee schedule

Payroll & mobility setup

From $999

fixed, quoted before work starts

Employer registration and withholding for staff on assignment, arranged before the first pay run rather than corrected after it.
See the fee schedule

Non-resident & departure filings

From $349

fixed, quoted before work starts

For anyone taxed by a country they do not live in — rent, pensions and investment income reaching across a border after the move.
See the fee schedule

All published fees on one page — all of it on a single page, so the number you compare is the number you pay.

What the reporting test actually looks at

What decides whether Form 3CEAB applies
What the test looks atWhere the figure comes from
The obligationThe intimation designating which Indian entity of a group will file the master file.
Who it bindsGroups with more than one Indian constituent entity.
Jurisdiction and authorityIndia — Income Tax Department
Category of filingInformation return

When it is due

Information returns are generally due with — or on the same timetable as — the return they accompany, so the deadline is the filing deadline of the underlying return unless the rules set a separate date. Where an extension covers the return, confirm whether it also covers this form; several information returns keep their own date. We diarise it from your own year end rather than from a generic calendar, because the two rarely coincide in a cross-border group.

What late or missed filing costs

The penalty on an information return is charged per form and per year, and it does not depend on tax being owed. That is the whole risk profile: a filer with no tax to pay can still accumulate a substantial liability across unfiled years, and the exposure compounds with each additional entity or account that should have been reported. Where years are already missed, the route chosen for the earliest year affects the relief available for the rest — so the sequence is decided before anything is filed.

A worked example

Numbers make this concrete, so here is the same rule applied to a set of figures.

Deduction on the price against tax on the gain

An NRI sells Indian property for ₹9,700,000 with an indexed cost of ₹5,723,000. Assume the buyer must deduct at 22% of the consideration, and assume tax on the gain at 22%.

Deduction on the price against tax on the gain
ItemAmount
Sale consideration₹9,700,000
Cost taken into account₹5,723,000
Gain actually arising₹3,977,000
Deduction on the consideration (assumed 22%)₹2,134,000
Tax on the gain (assumed 22%)₹874,940
Cash held back beyond the real tax₹1,259,060

₹1,259,060 more is deducted than the transaction actually owes. A lower-deduction certificate obtained before closing is what releases it at the table; without one it sits with the department until a return recovers it. We run this on your actual numbers before advising anything, because the conclusion can invert with a modest change in inputs.

These amounts illustrate the mechanism only. The rates and thresholds are assumptions of the example, not your numbers: each is checked against the issuing authority for your specific tax year before any return is filed.

How we prepare and file it, and what it costs

The fee for Form 3CEAB is fixed against a written scope and agreed before we start. It is not billed by the hour and it does not move after the fact. See the India ↔ United Kingdom — DTAA for comparable engagements.

What working with us looks like

  1. 1We establish what happened and when, because every position here is anchored to a date
  2. 2A written scope and a fixed price, so you know the cost before committing
  3. 3The filings are prepared, cross-checked against each other, and reviewed by name
  4. 4You see the result, approve it, and we file it
  • Documents move through an access-controlled portal rather than email.
  • Your existing accountant keeps the domestic file; we take the cross-border piece, with the boundary in writing.
  • Consultations scheduled to your working day rather than ours.

Whatever you have is enough to start the conversation, including nothing but the dates.

Reviewed for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. General guidance only. Your own facts decide the answer, so bring them to a call before relying on this.

Where double tax agreement India comes into this file

The subject here is Form 3CEAB, which is what people mean when they search for double tax agreement India. This page covers who it applies to, the filings it produces, and the fixed fee agreed before work begins.

A small procedural filing with a real consequence: without the designation, every Indian entity is exposed to the filing default rather than one.

From first contact to filed return

  1. Send the documents as they are

    No tidying required — forward what you have and we tell you what is missing.

  2. Get a fixed quote in writing

    Priced from your actual documents before any work begins, not estimated after.

  3. Both countries prepared together

    One team builds the filings against each other so the relief lands exactly once.

  4. Review, then file

    You approve the finished work before we file it.

The difference a dedicated cross-border team makes

Factor Legal Quotient Hourly billing model
Pricing A fixed fee, agreed in writing before work starts Hourly, billed as incurred
Experience 15+ years of cross-border work, 18,000+ clients Varies by file
Both sides of the border Prepared together by one team, so relief is claimed exactly once One country at a time, reconciled later
Who reviews it A named practitioner, published on the page Whoever the queue reaches
Where the work happens Our offices in India, the USA, Canada and the UAE Whichever single office you can travel to

Four terms worth pinning down

Clubbing of income
The Indian attribution of income back to a transferor where assets were transferred to a spouse or certain relatives without adequate consideration.
Presumptive taxation
An Indian scheme deeming profit as a percentage of turnover instead of computing it from books, with eligibility conditions and multi-year consequences.
Regulation 105
The Canadian withholding on fees paid to a non-resident for services rendered in Canada, computed on gross fees and reducible in advance by a waiver.
Specified foreign financial asset
The class of asset reportable on the US FATCA statement: foreign accounts, foreign-issued securities, interests in foreign entities and certain foreign contracts.
form 3ceab India: Our analysis

A small procedural filing with a real consequence: without the designation, every Indian entity is exposed to the filing default rather than one.

However the file develops, three things stay fixed: a written scope and fee before work begins, a named practitioner reviewing the result, and your approval before anything is filed.

Form 3ceab India — what the published fees look like

Filed on its own it is a self-contained piece of work; filed alongside the master file it usually sits inside that engagement. What changes the Form 3CEAB fee is history — a group that has never made the designation is looking at earlier years too, and until it does, every Indian entity carries the default rather than one.

Corporate cross-border filing

$999fixed, before work starts

Covers: Corporate compliance for a group that trades or holds assets in more than one country, prepared on both sides together.

See this fee page

Foreign asset & information reporting

$349fixed, before work starts

Covers: Disclosure of assets and interests held abroad, built once from a single asset list and filed on every side that asks for it.

See this fee page

Why clients bring form 3ceab India to us

We say early if it is not our work

If a file needs something this practice does not do, you hear that at the start rather than after a bill.

The fee is fixed before we start

Quoted from your documents and agreed in writing. The number you accept is the number you pay.

Both sides prepared together

Two returns built against each other by one team, so relief is claimed exactly once and nothing falls between the two systems.

Cross-border is the whole practice

International and cross-border tax is all we do — not a sideline next to domestic work. The edge cases on this page are our ordinary Tuesday.

Two of the firm’s advisers at the glass desk in the Delhi office

How the engagement runs, phase by phase

Step 1

Establishing the facts

We start with the chronology: dates, countries, and what has already been filed

Step 2

Agreeing the fee

You get the scope and the fee in writing before we touch anything

Step 3

Drafting and review

The work is prepared and reviewed by a named person, not a queue

Step 4

Filing and follow-up

Nothing is filed until you have read it

Two of the firm’s advisers at a desk in the Delhi office

The engagement, start to finish

  • Step 1: Hand over the paperwork in any state – Sorting it is our job. Send what exists and we identify what is missing from it.
  • Step 2: Priced before a single form is opened – The fee comes from the documents, agreed in writing, and stays where it was agreed.
  • Step 3: One position across every return – The same facts, filed consistently on each side, so nothing contradicts anything else.
  • Step 4: Filed after you have read it – The completed work reaches you before it reaches an authority.

Quoted up front, in writing.

Contact Us 24-hour helpline +1 (416) 619-0068

The rest of this practice

Each of these carries its own guide, pricing pointers and FAQ.

Services these clients use most

Holding company across borders Everything on holding company across borders, at the same depth as this page.
Paying royalties or licence fees abroad — withholding Paying royalties licence fees abroad withholding — the guide, the FAQ and the fixed fee.
FC-GPR & FC-TRS — inbound investment (India) The full guide to fc-gpr & fc-trs India, with the fee fixed before any work starts.
India ↔ Singapore — DTAA Its own page: India ↔ Singapore — DTAA — mechanism, deadlines and published fees.
Equalisation levy on digital services Everything on equalisation levy on digital services, at the same depth as this page.
Form 3CEAD — CbCR filing (India) Form 3cead India — the guide, the FAQ and the fixed fee.
Resale price & cost plus methods The full guide to resale price & cost plus methods, with the fee fixed before any work starts.
Form 2553 — S-corporation election Its own page: form 2553 s corporation election — mechanism, deadlines and published fees.
Amending a filed return — all three countries Everything on amending a filed return three countries, at the same depth as this page.

Who we help

Software developers — your filing calendar Everything on software developers your filing calendar, at the same depth as this page.
Investment funds cross-border tax Investment funds cross border tax — the guide, the FAQ and the fixed fee.
Civil & structural engineers — what you owe in each country The full guide to civil & structural engineers what you owe in each country, with the fee fixed before any work starts.
Day traders — your filing calendar Its own page: day traders your filing calendar — mechanism, deadlines and published fees.
Nurses working abroad — what you owe in each country Everything on nurses working abroad what you owe in each country, at the same depth as this page.
Cross-border truck drivers — relief you're probably missing Cross-border truck drivers relief you're probably missing — the guide, the FAQ and the fixed fee.
Management consultants — what you owe in each country The full guide to management consultants what you owe in each country, with the fee fixed before any work starts.
Twitch & live streamers — relief you're probably missing Its own page: twitch & live streamers relief you're probably missing — mechanism, deadlines and published fees.
Professors & lecturers — relief you're probably missing Everything on professors & lecturers relief you're probably missing, at the same depth as this page.

Countries and corridors this work reaches

Austria tax for expats — country guide Everything on Austria tax for expats, at the same depth as this page.
Uzbekistan tax for expats — country guide Uzbekistan tax for expats — the guide, the FAQ and the fixed fee.
Belgium tax for expats — country guide The full guide to Belgium tax for expats, with the fee fixed before any work starts.
Morocco tax for expats — country guide Its own page: morocco tax for expats — mechanism, deadlines and published fees.
Sri Lanka tax for expats — country guide Everything on Sri Lanka tax for expats, at the same depth as this page.
Ecuador tax for expats — country guide Ecuador tax for expats — the guide, the FAQ and the fixed fee.
Greece tax for expats — country guide The full guide to Greece tax for expats, with the fee fixed before any work starts.
US–Portugal tax corridor Its own page: US Portugal tax — mechanism, deadlines and published fees.
Switzerland tax for expats — country guide Everything on Switzerland tax for expats, at the same depth as this page.

The people on your file

Five named practitioners, each with the part of a cross-border file they carry. Every page on this site says who reviewed it, and the reviewer is one of these people rather than an unnamed team.

Udit Gupta

Udit Gupta

Cross-Border Tax Expert

CA (ICAI), In-Depth Tax Trained

Reviews and signs off the practice's cross-border positions, and carries final responsibility for the treaty analysis on every file that leaves the office.

Abhinav Gupta

Abhinav Gupta

Canada Tax / International Tax

Canada Tax, International Tax, Cross-Border Tax, Transfer Pricing

Canadian returns with foreign income, non-resident filings, and the transfer-pricing documentation that runs alongside intercompany work.

Raghav Gupta

Raghav Gupta

International Tax

International Tax, Transfer Pricing Specialist

Benchmarking, method selection and the local-file and master-file sets that support a group's pricing policy under examination.

Anmol Mittal

Anmol Mittal

Canada and US tax

CPA Canada, CPA USA, CA (ICAI)

Files that have to be right on both sides of the border at once — dual filings, streamlined catch-ups, and the foreign tax credit reconciliation between them.

Vinayak Indolia

Vinayak Indolia

CFO advisory

CPA, CA. Fractional CFO and Senior Advisory Specialist

Groups that need the tax position and the finance function to agree: structure reviews, intercompany policy, and the reporting a board can act on.

Meet the whole team

Files that look like this one

Case study 1

A US Citizen Settled in India, Filing on Both Sides

Residence in India and citizenship in the United States produce two annual returns for one income. The order decides the credit, and the Indian financial year and the US calendar year have to be reconciled before either is prepared.

Read how this one runs
Case study 2

Tax Deducted When Buying From an NRI

Withholding on a sale by a non-resident is applied to the sale value rather than to the gain, so it routinely exceeds the tax due. A lower-deduction certificate obtained before completion avoids locking the difference up.

Read how this one runs
Case study 3

Coming Back to Canada After Years Abroad

Returning restarts Canadian residence and re-values what you own on the day you arrive. Foreign pensions, employer plans and accounts opened abroad each land differently, and the reporting thresholds are tested against the whole portfolio rather than each account.

Read how this one runs
Case study 4

A Second Opinion on a Return Already Filed

A cross-border return prepared on one side only is usually right in isolation and wrong in combination. The review checks residence, source and relief in that order, and says plainly whether an amendment is worth making.

Read how this one runs
Case study 5

Deduction at Source on Deposit Interest, Recovered

Where the treaty rate is lower than what was deducted, the difference comes back through a return rather than at source. The file establishes entitlement and files for the years still open.

Read how this one runs
Case study 6

The Two-Year Window After Returning to India

Returning residents pass through a transitional status in which foreign income is largely outside the Indian net. The engagement establishes when the window opens and closes, and puts the transactions that benefit inside it.

Read how this one runs
Case study 7

A US Filer Married to Someone Outside the System

Electing to treat a non-resident spouse as a US filer buys joint rates and brings that spouse's worldwide income and foreign accounts into the return. The election is easy to make and hard to revoke, so both positions are modelled first.

Read how this one runs
Case study 8

A Company That Needed a Resident on Its Board

Several jurisdictions require a locally resident director before a company can be registered or keep its filings current. The requirement is structural and is settled at incorporation rather than discovered at the first annual return.

Read how this one runs

All case studies — every published engagement in one place.

Where we deliver this work

Every link below is a full page of its own — the same depth as this one, for its own subject.

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

Strategy and compliance for income, assets and families spread across borders.

One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.

U.S. & Cross-Border Tax Returns

Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.

Expat & Emigration Tax

The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.

Non-Resident Canadian Tax

Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.

Cross-Border Estates & Trusts

Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.

India Tax for NRIs & Returning Residents

The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.

Canadian Tax with a Foreign Element

Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.

UAE Tax for Expats & Their Home Country

A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

Industries & Client Types We Serve Worldwide

Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies

Global E-commerce & Marketplaces

  • Foreign VAT / GST / sales tax registrations
  • Marketplace withholding reviews
  • Inventory nexus & PE analysis
  • Multi-currency books reconciled
Explore E-commerce & Marketplaces

Technology & SaaS

  • Cross-border revenue sourcing & withholding
  • IP structuring with real substance
  • Equity for cross-border teams
  • U.S. expansion: entity & PE setup
Explore Technology & SaaS

Professional Services Firms

Firms and partners working across borders meet Regulation 105 withholding, PE risk on long engagements and per-country payroll for travelling staff.

A partnership is taxed in the hands of its partners, so one engagement abroad can reach every partner's personal return. The order matters: the waiver is applied for before the invoice, the presence is tracked before it becomes an establishment, and the payroll is registered before the first day worked in the other country.

  • Reg 105 / 102 waivers
  • Permanent establishment risk
  • Partner mobility planning
  • Cross-border withholding recovery
Explore Professional Services

Importers, Exporters & Manufacturers

  • Transfer pricing documentation (s.247)
  • Customs value vs transfer price
  • Foreign affiliate reporting (T1134)
  • Country-by-country reporting
Explore Trade & Manufacturing

Athletes, Artists & Entertainers

  • Reg 105 & U.S. CWA agreements
  • Multi-state & country calendars
  • Touring income allocation
  • Royalty & image-rights withholding
Explore Athletes & Entertainers

Remote Workers & Digital Nomads

  • Residency analysis before moving
  • Employer payroll exposure
  • Totalization & social security
  • Foreign tax credits
Explore Remote Workers

Investment Funds & Holding Companies

  • Treaty access & PPT reviews
  • FAPI & surplus computations
  • Withholding-efficient routing
  • Governance & substance
Explore Funds & Holdcos

Form 3CEAB — questions we are asked

Do I file Form 3CEAB even if no tax is owed?

Information return obligations of this kind are generally required on the facts rather than on the tax result, so a nil position does not remove one. Groups with more than one Indian constituent entity.

What happens if I have missed Form 3CEAB for several years?

Missed years are dealt with as a package rather than one at a time, because the route chosen for the first year affects the relief available for the rest. We map the years and the obligations before anything is filed.

Is Form 3CEAB the same as the other reports I already file?

No. The intimation designating which Indian entity of a group will file the master file. Satisfying a different obligation, even one covering the same accounts or entity, does nothing for this one.

What does a transfer pricing benchmarking study do?

It evidences that your related-party pricing sits within the range independent parties achieve. The work is comparison: identify companies or transactions genuinely similar in function, risk and assets, compute their margins, and show where your result falls against that range. Done before the filing deadline it supports the position; produced afterwards under audit it carries far less weight. See benchmarking study.

What is DTAA?

DTAA — a Double Taxation Avoidance Agreement — is India's term for a tax treaty. It allocates taxing rights between India and the other country, caps withholding on cross-border payments, and gives relief for income taxed twice by either exempting it or crediting the foreign tax. Relief is claimed, and from the Indian side that normally means a tax residency certificate, Form 10F and Form 67. See DTAA relief.

Can you give a plain transfer pricing example?

A Canadian company manufactures at a cost of one hundred and its US subsidiary sells to customers for one hundred and eighty. If the parent invoices the subsidiary at one hundred and ten, most of the margin is taxed in the United States; invoice at one hundred and seventy and most of it is taxed in Canada. Nothing about the business changed — only which treasury collects. That is why the arm's length price, the one unrelated parties would have agreed, is the reference point both authorities use. See our transfer pricing work.

Meet us in person at any of our offices

Get Form 3CEAB handled for a fixed fee

Describe what happened and which countries are involved; the fee comes back in writing before anything begins.

  • Re-quoted, never silently invoiced
  • A named reviewer signs off every filing
  • Your existing accountant keeps the domestic file

Our practitioners are alumni of leading accounting and tax institutions

Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.

Request a Quote +1 (416) 619-0068