The CBDT vide Rule 10DA has prescribed for maintenance and filing of Master File for certain companies. This post provides overview on the applicability of the Rule and data required for compliance.
The requirement of maintaining and filing Master File is applicable in the following situations:
a. Where the consolidated revenue of the International Group (of which your company is a Constituent Entity) as per the consolidated financial statement of the International group for the Accounting Year exceeds Rs 500 Crore; and
b. International transaction in FY 16-17 exceeds Rs 50 Crores or transactions related to IP exceed Rs 10 Crores.
International Group: International Group means any Group that includes two or more enterprises/companies which are resident of different countries or territories.
Constituent Entity: Constituent Entity means any separate entity which is included in the consolidated financial statement of the said International Group for financial reporting purposes.
Accounting Year: Accounting Year means an annual accounting period, with respect to which the parent entity of the international group prepares its financial statements
In case the above conditions are satisfied, the company will have to file both Part A and Part B of Form 3CEAA. In case the above conditions are not satisfied, only Part A of Form 3CEAA has to be filed. The details required for filing Part A and Part B of Form 3CEAA is attached.
In case there are more than one constituent entities resident in India, of an international group, then one entity may be designated by the international group to furnish Form 3CEAA Part A & B. Such entity shall intimate that it will furnish Form 3CEAA Part A & B by filing Form 3CEAB 30 days prior to 31.03.2018.
Please evaluate applicability of the above Rules and let us know if you require any assistance with respect to preparation and filing of Master File.