RSM India

Newsflash - Income Tax - Final Rules with respect to Country-by-Country reporting and furnishing of master file

We are pleased to release our newsflash on the captioned subject.


Under the Finance Act 2016, the Central Board of Direct Taxes (CBDT) had inserted section 286 in the Income Tax Act, 1961 to implement the recommendation of 2015 Final Report on Action 13, titled “Transfer Pricing Documentation and Country-by-Country Reporting”, identified under the OECD Base Erosion and Profit Shifting (BEPS) Project. CBDT had issued the draft rules in respect of Country-by-Country reporting and furnishing of master file for public comments on 6 October 2017. CBDT has issued the FINAL rules on 31 October 2017.

Highlights of the FINAL Rules:

  1. Every Person being constitute entity of the international group shall maintain and furnish information if the consolidated revenue of the international group for the accounting year, exceeds INR 500 Crore and the aggregate value of the international transaction during the reporting year, as per the books of accounts exceeds INR 50 Crore or in respect of purchase, sale, transfer, lease or use of intangible property during the reporting year, as per the books of accounts, exceeds INR 10 Crore.
  2. The threshold limit for filling of the Country-by-Country report would be applicable if the total consolidated group revenue exceeds INR 5,500 Crore.
  3. The due date for filling of the Master File and Country-by-Country reporting for the year ended 31 March 2017 is anytime on or before 31 March 2018.
  4. CBDT has issued a set for Forms namely Form 3CEAA to Form 3CEAE.

This newsflash summarizes the key provisions of the amended rules and we trust you will find the same useful.

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