In keeping with India's commitment to implement recommendations of 2015 Final Report on Action 13, titled "Transfer Pricing Documentation and Country-by-Country Reporting", the Department of Income Tax has invited comments from stakeholders and the general public.

It has said that these comments and suggestions on draft rules must be sent by October 16 electronically at e-mail
Rules on country-by-country reporting were identified under the OECD Base Erosion and Profit Shifting (BEPS) Project, Section 286 of the Income-tax Act, 1961 and 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.

Accordingly, subsequent to the aforesaid amendments to the Act, it has been 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 in the country-by-country report.

In this regard, draft notification providing for the insertion of rules 10DA & 10DB and form nos. 3CEBA to 3CEBE has been framed and uploaded on the website of the Department www.incometaxindia.gov.in for comments from stakeholders and general public, said Surabhi Ahluwalia, Commissioner of Income Tax (Media and Technical Policy) and official spokesperson of the CBDT.