Master File and CBC reporting
Introduction: Indian Income-tax law has come up with a three-tier documentation structure, by following the recommendations of Organization for Economic Cooperation and Development (OECD) under Action 13 of the Base Erosion and Profit Shifting (BEPS) project. The Finance Act, 2016 introduced Section 286 to the Income-tax Act, 1961 providing for furnishing of Country by Country (CbC) report in respect of an international group. Section 92D of the Act which contained provisions for preparing TP documentation was also amended to provide for the furnishing of Master File. Rules 10DA and 10DB have been inserted in the Income-tax Rules, 1962 (the Rules). Forms 3CEAA, 3CEAB, 3CEAC, 3CEAD, and 3CEAE have also been notified under the above rules. A. Rule 10DA (Section 92D) lays down the thresholds for applicability, timelines, requirements, and procedures in relation to Master File . The relevant information and intimation related to Mast...