IN pursuant to India's commitment to implement the recommendations of the Committee set up to insert rules 10DA, 10DB and form nos. 3CEBA to 3CEBE in the Income-tax Rules, 1962, the Central Board of Direct Taxes has notified the rules for maintaining and furnishing of transfer pricing documentation in the Master File and Country-by-Country report. Since it is the first reporting year for furnishing of the Country-by-Country report, the due date for filing the Country-by-Country report for reportable accounting year 2016-17 has already been extended to March 31, 2018. Similarly, the date of compliance for furnishing the Master File for FY 2016-17 has been extended to March 31, 2018 as a one-time relief measure.

The salient features of the Country-By-Country Report and Master File rules are as under:

•  The threshold for the Country-By-Country Report is total consolidated group revenue of Rs. 5,500 crore or more.

•  The threshold for the Master File is consolidated group 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.

•  Report of Master File has to be submitted in Form 3CEAA and the Country-by-Country Report in Form 3CEAD.

•  An international group having multiple Indian constituent entities may designate one constituent entity to file the Master File.

•  Part A of Form 3CEAA is to be filled by every constituent entity of an international group regardless of whether it qualifies under the threshold for furnishing Master File. However, to reduce the compliance burden, such international group having multiple Indian constituent entities can designate one constituent entity to file Part A on its behalf.

•  Form 3CEAD for furnishing Country-by-Country Report follows OECD template.

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