Country-by-Country Reporting & Furnishing of Master File (Transfer Pricing)- Latest Developments

2. The aggregate value of international transactions :

• During the accounting year, exceeds Rs. 50 Crore, or

• In respect of the purchase, sale, transfer, lease or use of intangible property, exceeds Rs. 10 Crore.

Requisite Information And Documents of The International Group (IG)

1. A list of all entities of the IG along with their addresses

2. A chart depicting the legal status of the constituent entity and ownership structure of the entire IG

3. A description of the business of IG during the accounting year including –

• Nature of the business

• Important drivers of profits of such business

• A description of the supply chain for the 05 largest products or services of the IG in terms of revenue and any other products including services amounting to more than 5% of consolidated group revenue

• A list and brief description of important service arrangements made among members of the IG other than research and development services

• A description of the capabilities of the main service providers within the IG

• Details about the Transfer Pricing Policies (TP) for allocating service costs and determining prices to be paid for intra-group services

• A list and description of the major geographical markets for the products and services offered by the IG

• A description of the functions performed, assets employed and risks assumed by the constituent entities of the IG that contribute at least 10% of the revenues or assets or profits of such group; and

• a description of the important business restructuring transactions, acquisitions and divestments;

4. A brief description of the overall strategy of the IG for the development, ownership and exploitation of intangible property, including the location of principal research and development facilities and their management.

5. A list of all entities of the IG engaged in development and management of intangible property along with their addresses.

6. A list of all the important intangible property or groups of intangible property owned by the IG along with the names and addresses of the group entities that legally own such intangible property

7. A list and brief description of important agreements among members of the IG related to intangible property, including cost contribution arrangements, principal research service agreements and license agreements

8. A detailed description of the TP Policies of the IG related to research and development and intangible property

9. A brief description of important transfers of interest in intangible property, if any, among entities of the IG, including the name and address of the selling and buying entities and the compensation paid for such transfers

10. A detailed description of the financing arrangements of the IG including the names and addresses of the top ten unrelated lenders

11. A list of group entities that provide central financing functions, including their place of operation and of effective management

12. A detailed description of the TP Policies of the international group related to financing arrangements among group entities

13. A copy of the annual consolidated financial statement (CFS) of the IG and

14. A list and the brief description of the existing unilateral advance pricing agreements (APAs) and other tax rulings in respect of the IG for allocation of income among countries.

Further, the information in Form No. 3CEAA for the accounting year 2016-17 may be furnished at any time on or before the 31st day of March 2018.

Shall be furnished by every person, being a constituent entity of an IG.

2. Part B of Form No. 3CEAA

Shall be furnished by a person, being a constituent entity of an IG, in those cases where the conditions as provided in sub-rule (1) are satisfied.

1. whether it is the alternate reporting entity of the IG; or

2. The details of the parent entity or the alternate reporting entity, as the case may be, of the IG & the country or territory of which the said entities are residents.