Rule 10DA – Requirements for filing a Master File as per CBDT Notification (N.No. 3497(E))
The Central Board of Direct Taxes (CBDT), has released the final rules through a notification (N No. 3497(E) on preparation and filing of Master file by the Indian Entity of an International group. The brief of the rules as notified and the documentation/information requirements as needed for the filing are summarized herewith for your reference.
For a deeper discussion of how this would be relevant for your entity, please contact the undersigned.
Preparation and filing of master file with the income tax department is mandatory for those Indian entities which are a part of the international group (whether a parent company is Indian resident or a foreign resident).
|Conditions||Threshold limit in INR Crores|
|A||Consolidated group revenue of the ‘International Group’ for the accounting year EXCEEDS||500|
|B||Aggregate Value of International Transactions EXCEEDS||50|
|C||International transaction pertaining to an intangible property EXCEEDS||10|
Condition A is to be fulfilled first and then any of the one condition is to be fulfilled out of B & C for the applicability of master file requirement.
Ø Requirements under the relevant form
(Republished with Amendments)