Business Updates
Country-by-Country Report (CbCR) for Transfer Pricing Under Section 286 of the Income Tax Act
Finance Act, 2016 introduced a new Section - Section 286 of Income-tax Act, 1961 (the Act) providing for furnishing of Country-by-Country Report (CbCR) in respect of an International Group. Further, Section 92D of the Act which contained provisions for preparing TP documentation is also amended to provide for keeping and maintaining of Master File. The compliances for FY 2016-17, if the above provisions are applicable to the Group are to be completed by 31st March, 2018.
A brief overview of thresholds for applicability and forms to be filed is summarized hereunder:
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Particulars |
Applicability to MNC Group |
Forms applicable |
Due Dates for FY 2016-17 |
|
Masterfile (Section 92D rw Rule 10DA) |
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(PART A applicable to all MNCs irrespective of thresholds)
|
31st March, 2018
1st March, 2018 |
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b) Purchases/ Sale/ transfer/ lease/use of intangible exceeds 10 crores |
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CbC Reporting (Section 286 rw Rule 10DB)
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Consolidated Group Revenue exceeds Rs 5500 Crores. |
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31st January, 2018 31st March, 2018 31st March, 2018
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We have summarized the above provisions and requirements of rules in the attachments as under:
- Deadlines for the master file and CBCR Compliances.
- Forms and details to be filed.
- Checklist of information to be collated or created.
- Procedure and risk assessment for MF and CBCR compliances.
- Penal Consequences of non filing.
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