CBDT Notifies The Final Rules For Enhanced Transfer Pricing Documentation - Master File And CbCR

The Central Board of Direct Taxes (CBDT) had released draft rules for Master File and Country-by-Country Report (CbCR) requirements on 6 October and has requested for comments from the public.

To know more about the provisions in the draft rules,  please click here.

On 31 October, the CBDT notified the final rules laying down the applicability criteria and requirements for maintaining and furnishing the enhanced transfer pricing documentation requirements in the nature of Master File and CbCR. Notably, there were a few suggestions, including a major concern that the threshold of INR 5 billion was quite low for Master File applicability. However, the provisions in the final rules are largely in line with the provisions stipulated in the draft rules.