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CBDT to modify advance ruling forms for transparency in cross-border deals
April, 16th 2018

The tax department on Saturday said it will modify the forms for advance ruling in order to bring greater transparency in cross-national transactions.

The Central Board of Direct Taxes (CBDT) today invited comments on draft notification proposing amendment to Rule 44E, Form 34C, 34D and 34DA as per BEPS Action 5, for improving transparency in tax rulings.


Under Base Erosion and Profit Shifting (BEPS) Action 5, exchange of rulings on Permanent Establishment (PE) by Authority for Advance Rulings is required to be done not only with the countries of residence of all related parties with whom a taxpayer enters into transaction, but also with the country of residence of the immediate parent company and the ultimate parent company.

"Therefore, in order to implement the recommendations made under Action 5 of BEPS Action Plan to bring greater transparency in cross-national transactions, Form 34C and 34D (Forms for Advance Rulings) are required to be modified so that details such as name, address and country of the residence of non-resident's immediate parent company or ultimate parent company etc. are captured at application stage itself," the CBDT said.

The comments and suggestions on the draft rules and forms have to be sent by April 30 to the e-mail address - ts.mapwal@nic.in.

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