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TRANSFER PRICING - Country By Country ( CbC ) reporting - budget 2016

TRANSFER PRICING - Country By Country (CbC ) reporting - budget 2016 - Budget - By: - CS Swati Dodhi - Dated:- 1-3-2016 - TRANSFER PRICING Introduction by country by country reporting requirements Revised standards for transfer pricing documentation and a template for country-by-country reporting of income, earnings, taxes paid and certain measure of economic activity was provided in The OECD report on Action 13 of Base Erosion and Profit Shifting ( BEPS ) Action plan. India has been one of the .....

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on requirements. Amendments for introduction of CbC Reporting are proposed to be made in the Act and the Rules thereunder. The elements relating to CbC reporting requirement and matters related to it proposed to be included through amendment of the Act, by virtue of introduction of Section 286 of the Act, are as below - Entities to which CbC Reporting would apply The reporting provision shall apply in respect of an international group having consolidated revenue above a threshold to be prescribe .....

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dia, shall be required to furnish the report in respect of the group to the prescribed authority on or before the due date of furnishing of return of income for the Assessment Year relevant to the Financial Year (previous year) for which the report is being furnished (which at present is November 30 for the tax year ended on March 31); In case of an international group whose parent entity is not situated in India, the constituent entity of the said international group, shall provide information .....

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ch country or territory along with details of each constituent's residential status, nature and detail of main business activity and any other information as may be prescribed. The prescribed authority has been empowered to call for such document and information from the entity furnishing the report for the purpose of verifying the accuracy of the CbC report. A time period of 30 days has been laid down for fulfillment of such request. Filing of the CbC Report by specified entities An entity .....

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respect of furnishing the CbC Reports with the prescribed authority. Penal provisions in case of failure to furnish the CbC report. Default For non-furnishing of the report by an entity which is obligated to furnish it - Default of upto one month ₹ 5,000 per day whereas Default is beyond one month ₹ 15000 per day for the period exceeding one month Default for For non-furnishing of the report by an entity which has been served a penalty order, as per (1) above - Default for days beyo .....

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