The Action 13 report of the Organisation for Economic
Co-operation and Development's (OECD's) Base Erosion and
Profit Shifting (BEPS) project introduced to transfer pricing
documentation, consisting of:
- Master File,
containing information relevant for all members of the
Multinational Enterprise (MNE) group;
- Local file,
referring specifically to material transactions of the local
taxpayer; and
- Country-by-Country Reporting
(CbCR), containing certain information relating to the
global allocation of the group's income and taxes, together
with indicators of the location of economic activity within the
group (CbCR information).
Applicability of CbCR:
In India, CbCR filings have been made applicable from Financial
Year 2016-17 (April 2016 to March 2017) subject to meeting the
consolidated revenue threshold criteria of INR 5 billion. For
further details on applicability refer our alert
click here.