The Central Board of Direct Taxes (CBDT) on 1 November 2017 notified the rules for maintaining and furnishing the Master File and Country-by-Country Report.
The due date for filing the Country-by-Country report and furnishing the Master File for reportable accounting year 2016-17 is 31 March 2018.
Highlights of Country-By-Country Report and Master File rules
• The threshold for the Country-By-Country Report is total consolidated revenue of Rs 5500 crore or more.
• The threshold for the Master File is consolidated revenue exceeding Rs 500 crore and either the aggregate value of international transactions as per the books of accounts exceeding Rs 50 crore or aggregate value of international transactions in respect of intangible property exceeding Rs 10 crore.
• The report of Master File needs to be submitted in Form 3CEAA and the Country-by-Country Report in Form 3CEAD.
• An international group having multiple Indian constituent entities can designate one constituent entity to furnish the Master File.
• Part A of Form 3CEAA is needed to be filled by every constituent entity of an international group. However, the international group having multiple Indian constituent entities can designate one constituent entity to file Part A on its behalf to reduce the compliance burden.
• Form 3CEAD for furnishing Country-by-Country Report follows OECD template.
As per the recommendations of 2015 Final Report on Action 13 titled “Transfer Pricing Documentation and Country-by-Country Reporting”, section 286 of the Income-tax Act, 1961 was inserted vide Finance Act, 2016, providing for furnishing of a Country-by-Country report.
Section 92D of Income-tax Act, 1961 was also amended vide Finance Act, 2016 to provide for keeping and maintaining of Master File by every constituent entity of an international group, which was to be furnished as per rules prescribed.
Subsequently, comments and suggestions were invited on the proposal to insert rules 10DA, 10DB and form nos. 3CEBA to 3CEBE in the Income-tax Rules, 1962 for laying down the guidelines.
After a thorough examination, the CBDT notified the rules for maintaining the Master File and Country-by-Country report.
When: 1 November 2017
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