How it works
Singapore requires CbCR only from Singapore-headquartered groups with revenue of at least S$1,125 million. Pillar Two top-up taxes apply to groups with revenue of at least EUR 750 million in two of the four preceding years. In India, from 1 April 2026, the forms are renumbered: Form 56 (master file), 57, 58 (CbCR intimation), 59 (CbCR) and 60. Part A of the master file has no threshold; Part B applies above INR 500 crore of group revenue and INR 50 crore of international transactions; CbCR applies above INR 6,400 crore.
Worked example
A group headquartered elsewhere with S$900 million revenue and an Indian entity transacting INR 60 crore internationally, group revenue INR 5,200 crore: no Singapore CbCR, no Pillar Two, Indian master file Part A and Part B required, no Indian CbCR.
Questions people ask
Does a Singapore subsidiary file CbCR in Singapore?
Not if the group is headquartered elsewhere.
Which Indian forms replaced 3CEAA to 3CEAE?
Forms 56 to 60, from 1 April 2026.
Is there a threshold for master file Part A?
No. Every Indian constituent entity of an international group files it.
Sources
- IRAS: Country-by-country reporting
- IRAS: Registration for MTT and DTT (Pillar Two)
- Treelife: Master file and CbCR in India, old and new formssecondary
- CAclubindia: Forms 56 to 60 under the Income-tax Act, 2025secondary
Last checked 1 November 2026. General information only, not advice for your situation. Speak to a qualified adviser before you act.