India-US sign Inter-Governmental Agreement for exchange of
CbCR
Under Indian Transfer Pricing regulations constituent entities
of multinationals groups must file a Country by Country
Report('CbCR')in India if the MNE has consolidated revenue
of more than INR 5500 crores (approximately USD 825 Million/ 750
Million Euros) in the previous year.
In a recent development, India and US have signed an
Inter-Governmental Agreement on 27th March 2019 ('The
Agreement') for exchange ofCbCRs. This shall enable authorities
to automatically exchange CbCR filed in the jurisdiction of the
Ultimate Parent Entity for the years commencing on or after January
1, 2016.
India CbCR regulations
Generally, an Indian constituent entity (of an MNE group
headquartered overseas) is required to file only an intimation
reporting details of the parent or alternate reporting entity in
Form No 3CEAC. Thereafter, Indian authorities shall source CbCR
through the exchange of information
