10 July 2018

Indian Tax Administration releases guidance on appropriate use of Country-by-Country reports

The Indian Government, through Finance Act, 2016, amended the Indian income tax law (ITL) to introduce provisions for additional transfer pricing (TP) documentation, consisting of: (i) a master file containing standardized information relevant for all members of a multinational group; and (ii) a Country-by-Country (CbC) report 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). The amendments were introduced to implement the recommendations contained in the Organisation for Economic Co-operation and Development's (OECD's) Base Erosion and Profit Shifting (BEPS) report on Action 13 (Transfer Pricing Documentation and Country-by-Country Reporting).

A Global Alert, attached below, provides additional details.

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ATTACHMENT

Document ID: 2018-1371