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.
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