Country-by-Country reporting requirement – CBDT notifies Final Rules:

(For International groups/entities – Indian & Foreign)

Finance Act, 2016 had amended Section 92D of the Income-tax Act, 1961 (‘the Act’) and introduced Section 286 to provide certain requirements regarding keeping, maintaining and furnishing information & documents in relation to International groups and its constituent entities. Such information reporting is termed as “Master File” and ‘Country-by-Country report (CbCR)”

CBDT vide Notification dated 31st Oct, 2017 (copy attached) has prescribed Final Rules, viz. New Rule 10DA & 10DB regarding such reporting requirements by way of preparation of a ‘Master File’ and “CbCR” by the parent entity or constituent Indian entities or Alternate reporting entity of an International Group. The above notification has also prescribed the Forms for the above reporting being Form 3CEAA, Form 3CEAB, Form 3CEAC, Form 3CEAD and Form 3CEAE and timelines for filing of the same.

Some reporting requirements are subject to certain limits of the consolidated group revenue of the international group and/or international transactions of the constituent Indian entity as prescribed in Rule 10DA/10DB. However, information in Form 3CEAA – PART A is to be furnished irrespective of any limits of revenue by constituent entity of the International group resident in India or designated constituent entity where there are more than one constituent entities of the International group in India.

For details kindly refer to the attached notification.

The above is for your information and compliance.

This applies to International groups being foreign company or group that has even one Indian company as subsidiary or joint venture and similarly to Indian group that have even one foreign entity as a subsidiary or joint venture.