ACTING on the BEPS recommendations relating to Action 13, titled “Transfer Pricing Documentation and Country-by- Country Reporting”, CBDT had inserted section 286 in the Income-tax Act, 1961 vide Finance Act, 2016, providing for furnishing of a Country-by-Country report in respect of an international group by its constituent or parent entity.
Section 92D of the Act was also amended vide Finance Act, 2016 to provide for keeping and maintaining of Master File by every constituent entity of an international group, which was to be furnished as per rules prescribed in this regard.
Consequent to these amendments to the Act, the CBDT has proposed to insert rules 10DA, 10DB and form nos. 3CEBA to 3CEBE in the Income-tax Rules, 1962, laying down the guidelines for maintaining and furnishing of transfer pricing documentation in the Master File and Country-by-Country report.
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