Framing of rules in respect of Country-by-Country reporting and furnishing of master file – comments and suggestions-reg

F. No. 370142/25/2017-TPL

Government of India

Ministry of Finance

Department of Revenue

Central Board of Direct Taxes


New Delhi, Dated 6th October, 2017

Subject: Framing of rules in respect of Country-by-Country reporting and furnishing of master file – comments and suggestions-reg.

In keeping with India’s commitment to implement the recommendations of 2015 Final Report on Action 13, titled “Transfer Pricing Documentation and Country-byCountry Reporting”, identified under the OECD Base Erosion and Profit Shifting (BEPS) Project, section 286 of the Income-tax Act, 1961 (‘the Act’) was inserted vide Finance Act, 2016, providing for furnishing of a Country-by-Country report in respect of an international group by its constituent or parent entity. Section 92D of the Act was also amended vide Finance Act, 2016 to provide for keeping and maintaining of Master File by every constituent entity of an international group, which was to be furnished as per rules prescribed in this regard.

2. Consequent to the aforesaid amendments to the Act, it is proposed to insert rules 10DA, 10DB and form nos. 3CEBA to 3CEBE in the Income-tax Rules, 1962 (‘the Rules’), laying down the guidelines for maintaining and furnishing of transfer pricing documentation in the Master File and Country-by-Country report. In this regard, the following guidelines are proposed to be prescribed:

Whole text of the circular can be accessed here 

3. The comments and suggestions of stakeholders and general public on the above draft notification are invited. The comments and suggestions may be sent electronically by 16th October, 2017 at the email address

(Sanyam Joshi)


Tel: 011-23095468


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