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Draft - Framing of rules in respect of Country-by-Country reporting and furnishing of master file comments and suggestions-reg.

Income Tax - F. No. 370142/25/2017-TPL - Dated:- 6-10-2017 - F. No. 370142/25/2017-TPL Government of India Ministry of Finance Department of Revenue Central Board of Direct Taxes ******* New Delhi, Dated 6th October, 2017 Subject: Framing of rules in respect of Country-by-Country reporting and furnishing of master file - comments and suggestions-reg. In keeping with India s commitment to implement the recommendations of 2015 Final Report on Action 13, titled Transfer Pricing Documentation and Co .....

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was to be furnished as per rules prescribed in this regard. 2. Consequent to the aforesaid amendments to the Act, it is proposed to insert rules 10DA, 10DB and form nos. 3CEBA to 3CEBE in the Income-tax Rules, 1962 ( the Rules ), laying down the guidelines for maintaining and furnishing of transfer pricing documentation in the Master File and Country-by-Country report. In this regard, the following guidelines are proposed to be prescribed: 2.1 The following rules 10DA and 10DB are proposed to b .....

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eceding such previous year, exceeds five hundred crore rupees; and (ii) the aggregate value of international transactions,__ (A) during the reporting year, as per the books of accounts, exceeds fifty crore rupees, or (B) in respect of purchase, sale, transfer, lease or use of intangible property during the reporting year, as per the books of accounts, exceeds ten crore rupees, keep and maintain the following information and documents of the international group:- (a) a list of all the operating e .....

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nternational group in terms of revenue plus any other products and/or services amounting to more than five per cent. of group turnover or revenue; (IV) a list and brief description of important service arrangements among members of the international group, other than those for research and development services; (V) a description of the capabilities of the main service providers within the international group; (VI) details about the transfer pricing policies for allocating service costs and deter .....

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divestments during the accounting year; (d) a description of the overall strategy of the international group for the development, ownership and exploitation of intangibles, including location of principal research and development facilities and their management; (e) a list of all the entities of the international group engaged in development and management of intangibles along with their addresses; (f) a list of all the important intangibles or groups of intangibles owned by the international g .....

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ers of interest in intangibles, if any, among entities of the international group, including the name and address of the selling and buying entities and the compensation paid for such transfers; (j) a detailed description of the financing arrangements of the international group, including the names and addresses of the top ten unrelated lenders; (k) a list of group entities that provide central financing functions, including their place of operation and of effective management; (l) a detailed de .....

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shall be furnished to the Director General of Income-tax (Risk Assessment) on or before the due date for furnishing the return of income as specified in sub-section (1) of section 139: Provided that the information in Form No. 3CEBA for the reporting accounting year 2016-17 may be furnished at any time on or before the 31st day of March, 2018. (3) Information,__ (i) in Part A of Form No. 3CEBA shall be furnished by every person, being a constituent entity of an international group; (ii) in Part .....

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t) in Form 3CEBE. (5) The notification referred to in sub-rule (4) shall be made at least 30 days before the due date of filing the report as prescribed under sub-rule (2) above. (6) The Principal Director General of Income-tax (Systems) or Director General of Income-tax (Systems), as the case may be, shall specify the procedure for electronic filing of Form No. 3CEBA and shall also be responsible for evolving and implementing appropriate security, archival and retrieval policies in relation to .....

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purposes of sub-section (1) of section 286, every constituent entity resident in India, shall, if its parent entity is not resident in India, notify the Director General of Income-tax (Risk Assessment) in Form 3CEBB, the following, namely:- (a) whether it is the alternate reporting entity of the international group; or (b) the details of the parent entity or the alternate reporting entity, as the case may be, of the international group and the country or territory of which the said entities are .....

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of an international group, resident in India, other than the entity referred to in sub-rule (3), shall furnish the report referred to in sub-rule (3) within the time specified therein if the provisions of sub-section (4) of Section 286 are applicable in its case. (5) If there are more than one constituent entities of an international group, resident in India, other than the entity referred to in sub-rule (3), then the report referred to in subrule (4) may be furnished by that entity if it has b .....

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rm No. 3CEBB, Form No. 3CEBC and Form No. 3CEBD and shall also be responsible for evolving and implementing appropriate security, archival and retrieval policies in relation to the information furnished under this rule. (8) The terms accounting year‟, alternate reporting entity‟, consolidated financial statement‟, international group‟ and reporting accounting year‟ shall have the same meaning as assigned in sub-section (9) of Section 286. 2.2 Forms 3CEBA to 3CEBE, a .....

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f which the assessee is a constituent entity- 6. Number of constituent entities of the international group operating in India - 7. Name, permanent account number and address of all the Constituent Entities included in item no. 6 Serial Number Name of the constituent entities of the international group Permanent account number of the constituent entities of the international group Address of the constituent entities of the international group PART - B List of a .....

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of profits of such business or businesses; (iii) a description of the supply chain for the five largest products or services of the international group in terms of revenue and any other products and services amounting to more than five per cent. of the group revenue or turnover; (iv) a list and brief description of important service arrangements among members of the international group, other than those for research and development services; (v) a description of the capabilities of the main serv .....

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a description of the important business restructuring transactions, acquisitions and divestments during the reporting accounting year; 4. Description of the overall strategy of the international group for the development, ownership and exploitation of intangibles, including location of principal research and development facilities and their management- 5. List of all the entities of the international group engaged in development of intangibles and in management of intangibles along with their ad .....

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ements among members of the international group related to intangibles, including cost contribution arrangements, principal research service agreements and license agreements - 8. Description of the transfer pricing policies of the international group related to research and development and intangibles - 9. Description of important transfers of interest in intangibles, if any, among entities of the international group, including the names and addresses of the selling and buying entities and the .....

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olidated financial statement of the international group- 14. A list and brief description of the existing unilateral advance pricing agreements and other tax rulings in respect of the international group for allocation of income among countries - I …………………………………………… son/daughter/wife* of Shri …………………………&hellip .....

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rant …………………………… PAN of the declarant Note: *Strike off whichever is not applicable FORM NO. 3CEBB [See rule 10DB] Notification Report by a constituent entity, resident in India, of a non-resident international group for the purposes of sub-section (1) of Section 286 of the Income-tax Act, 1961 1. Name of the constituent entity 2. Address of the constituent entity - 3. Permanent account number of the constituent entity .....

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nate reporting entity (ii) Address 10. Country of residence of the alternate reporting entity - I ……………………………………………… son/daughter/wife* of Shri ……………………………… hereby declare that I am furnishing the information in my capacity as …………………&hellip .....

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is not applicable FORM NO. 3CEBD [See rule 10DB] Notification on behalf of the international group for the purposes of the proviso to sub-section (4) of section 286 of the Income-tax Act, 1961 1. Name of the international group- 2. Name of the parent entity of the international group - 3. Address of the parent entity of the international group 4. Name of the constituent entity designated to furnish the report under sub-section (4) of Section 286 of the Income-tax Act, 1961 - 5. Address of the co .....

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;………… son/daughter/wife* of Shri ……………………………… hereby declare that I am furnishing the information in my capacity as …………………………… (designation) of ……………………………… (name of the assessee) and I am competent to furnish the said informa .....

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