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India: Final rules on country-by-country reporting, Master file requirements

India: Final rules on country-by-country reporting

The Central Board of Direct Taxes on 31 October 2017 released final rules concerning country-by-country (CbC) reporting.


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In addition to the final CbC rules, there are measures for implementing Master file requirements.

In general, these releases reflect India’s commitment to implement recommendations of Action 13 of the base erosion and profit shifting (BEPS) project. The Finance Act, 2016 introduced section 286 to the Income-tax Act, 1961 and requires the preparation and furnishing of a CbC report by certain international corporate groups. Section 92D of the tax law (that is, the provision concerning transfer pricing documentation) was amended to require Master file preparation.


Read a November 2017 report [PDF 444 KB] prepared by the KPMG member firm in India

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