RSM India

Transfer Pricing - CBDT prescribes 31 March 2019 deadline for entities in jurisdictions not having CbCR-exchange agreement

Central Taxes (CBDT) had prescribed 12 month time period under Rule 10DB(4) for furnishing Country by Country Reporting (CbCR) by constituent entity of an international group resident in India under specified circumstances u/s 286(4).

CBDT considered the stakeholder representations that the constituent entity of an international group, resident in India, having parent entity resident in jurisdictions with which India does not have an agreement providing for exchange of CbCR and where the reporting accounting year is calendar year based. i.e. ending on December 31 of the year would need to furnish CbCR by 31 December 2018; CBDT also considers that for reporting accounting year ending on 31 March 2017, the constituent entity would have been required to furnish the CbCR by 31 March 2018 which is not plausible

In order to remove the genuine hardship in furnishing of the report under sub-section (4) of section 286 of the Act read with sub-rule (4) of rule 10DB of the Rules caused as above, and a onetime measure, CBDT, in exercise of powers conferred under section 119 of the Act, has extended the period for furnishing of said report by the constituent entities referred to under clause (a) or (aa) of said sub-section, in respect of reporting accounting years ending up to 28 February 2018 to 31 March 2019.

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