Latest Expert Exchange Queries

GST Demo Service software link: https://ims.go2customer.com
Username: demouser Password: demopass
Get your inventory and invoicing software GST Ready from Binarysoft info@binarysoft.com
sitemapHome | Registration | Job Portal for CA's | Expert Exchange | Currency Converter | Post Matrimonial Ads | Post Property Ads
 
 
News shortcuts: From the Courts | News Headlines | VAT (Value Added Tax) | Placements & Empanelment | Various Acts & Rules | Latest Circulars | New Forms | Forex | Auditing | Direct Tax | Customs and Excise | ICAI | Corporate Law | Markets | Students | General | Mergers and Acquisitions | Continuing Prof. Edu. | Budget Extravaganza | Transfer Pricing | GST - Goods and Services Tax
 
 
 
 
Popular Search: due date for vat payment :: ACCOUNTING STANDARD :: TDS :: ARTICLES ON INPUT TAX CREDIT IN VAT :: articles on VAT and GST in India :: form 3cd :: empanelment :: list of goods taxed at 4% :: cpt :: VAT RATES :: Central Excise rule to resale the machines to a new company :: VAT Audit :: ICAI offer Get Windows 7,Office 2010 in Rs.799 Taxes :: ACCOUNTING STANDARDS :: TAX RATES - GOODS TAXABLE @ 4%
 
 
« Transfer Pricing »
 Govt eases transfer pricing norms for offshore funds
 India’s final transfer pricing master file rules retain unique flavor
 Transfer pricing: tighter reporting norms for multinationals notified
 Transfer pricing once again comes to the fore for MNCs
 Valuation rules under GST could lead to transfer pricing disputes
 A web of requirements in transfer pricing regime
 RBI panel reveals ad hoc, arbitrary practices by banks to inflate interest rates
 Taxman tightens reporting norms for MNCs
 Sabh Infrastructure Ltd Vs. Asstt. Commissioner Of Income Tax
 Transfer Pricing For Multinational Entities
 The wash up - Transfer pricing and the Commissioner of Taxation
 Bosnia's Serb Republic tax body looks into transfer pricing in Nestro Group - report
 Catherine Harlow is new head of transfer pricing at AstraZeneca
  Transfer Pricing Adjustments - The Current Irish Landscape

Transfer pricing once again comes to the fore for MNCs
October, 31st 2017

Aligning the Indian tax environment with global best practices and standards, the Central Board of Direct Taxes (CBDT) has yet again brought a change to transfer pricing documentation.

Aligning the Indian tax environment with global best practices and standards, the Central Board of Direct Taxes (CBDT) has yet again brought a change to transfer pricing documentation. Detailed transfer pricing rules have been issued for public discussions, which require MNCs operating in India to furnish documentation with respect to their worldwide operations, popularly known as Country-by-Country Reporting (CbCR) and Master File.


Who stands impacted?
The draft rules primarily deal with documentation requirements for domestic MNCs and subsidiaries of international MNCs operating in India. Going forward, these corporates will have to maintain two sets of documentation, i.e. the Master File and CbCR, if they meet the thresholds of turnover or international transactions. The CbCR is required to be maintained by domestic MNCs operating in India having a consolidated group revenue of Rs 5,500 crore or more, in the preceding accounting year. The requirements to prepare Master File shall apply to both domestic MNC groups and to subsidiaries of foreign MNCs operating in India, having a consolidated group turnover of over Rs 500 crore and satisfaction of either of the two conditions, i.e. (1) the international related party transactions of the entity exceeds Rs 50 crore, or (2) its intangible related transaction exceeds `10 crore.

How does it change the compliance burden?

The CbCR is required to be presented in a tabular format, setting out crisp information about the functions performed, assets owned, personnel employed, revenue generated, profits earned, taxes paid, capital structure, retained earnings, etc, with respect to each entity of the MNC group located in different countries. The Master File is expected to contain a blueprint of an MNC group’s global business model, specifically covering aspects such as organisational structure, description of various businesses, intangibles used in businesses, inter-company financial transactions, and financial and tax positions.

What are the deadlines?

The group parent entity in India is required to maintain a detailed CbCR and file the same by November 30 of the following year. Thus, for FY2016-17, the due date of filing the CbCR shall be November 30, 2017. The Indian subsidiary shall be required to maintain a Master File and furnish the same by the due date for filing return of income. However, for FY2016-17, the due date has been extended till March 31, 2018.

How this impacts domestic MNCs?

Given the threshold of Rs 500 crore for the preparation of a Master File, a lot of relatively small and mid-sized companies are likely to get impacted by this new development. This could possibly also result in situations requiring international groups to prepare a Master File only for India, since some of them may not actually have any such requirement under the laws of their respective countries. The preparation of a Master File shall require significant resources and careful planning on part of the management. Interestingly, even domestic MNCs that do not meet the thresholds of preparation of a Master File shall be required to file limited information in Part-A of the prescribed Form 3CEBA by the due date.

What is the immediate to-do for domestic MNCs?

Both the Master File and CbCR have relevance for the ultimate parent of the MNC. Thus, domestic MNCs need to gear up as the requirement for compliance has already commenced effective April 1, 2016. It is critical for MNCs to carry out a clinical analysis of their businesses at the earliest to find out whether there are any exposures in terms of mismatches between reported tax and business positions, value drivers, functions, rewards and risks, which might not have been detected during the course of normal local transfer pricing documentations carried out thus far, and take corrective measures with respect to supply chain models, as the new regulations get enacted.

 

 
 
Home | About Us | Terms and Conditions | Contact Us
Copyright 2017 CAinINDIA All Right Reserved.
Designed and Developed by Binarysoft Technologies Pvt. Ltd.
Publishing Management System PMS News Management System Publishing Management System Development Online News Management System for media company custom Publishing management system development Survey management system Market Res

Transfer Pricing | International Taxation | Business Consulting | Corporate Compliance and Consulting | Assurance and Risk Advisory | Indirect Taxes | Direct Taxes | Transaction Advisory | Regular Compliance and Reporting | Tax Assessments | International Taxation Advisory | Capital Structuring | Withholding tax advisory | Expatriate Tax Reporting | Litigation | Badges | Club Badges | Seals | Military Insignias | Emblems | Family Crest | Software Development India | Software Development Company | SEO Company | Web Application Development | MLM Software | MLM Solutions