CBDT Releases The Draft Master File And Cbcr Rules – Global Transfer Pricing Documentation Is A Reality Now

In what is considered to be one of the most fundamental changes in the international tax framework of this century, the Base Erosion and Profit Shifting (BEPS) project of the OECD/G20 had provided for a three-tier transfer documentation structure consisting of a Master File, Local File and Country-by-Country Report (CbCR) under Action plan 13.

To demonstrate India's commitment to the BEPS Action Plans, the Indian Finance Act, 2016 has adopted OECD's framework and the revised transfer pricing documentation and CbC reporting is made effective from the Financial Year (FY) 2016-17. However, the exact contours and rules with respect to the CbCR and Master File requirement were much awaited by the multinational groups.