CBDT Rules with respect to Country By Country Reporting

1. Requirement under IT Act Pursuant to OECD’s BEPS Action Plan 13
Master File CBCR File
Report to be furnished under sub
section (4) of section 92D read
with rule 10DA of the IncomeTax
Act, 1961
Report by a parent entity or an
alternate reporting entity or any
other constituent entity, resident in
India, for the purposes of sub-section
(2) or sub-section (4) of section 286
of the Income-tax Act, 1961
On or
Before 31st
March,
2018
On or
Before
31st March,
2018
Where
consolidated
group
revenue(FY
2015-16) >
5500 Crores.
If during FY 2016-17
1.Consolidated
Group Revenue >
500 Crores
And
2.Aggregate value of
International
Transactions
* as per books of
accounts > 50
Crores
Or
*with respect to
Intangible Property >
10 Crores
Yes
No
File Form 3CEAA
File Only Part-A of Form
3CEAA
Yes
No
File Form 3CEAD
No Action Required
Kindly note that forms are not available till date on the Income Tax Website
Penalty of Rs. 5 Lacs u/s 271AA in case of non-
compliance with Master File Provision.
*Penalty u/s 271GB Rs. 5K if failure < 1 month; Rs. 15K for failure > 1 month; in case of
non compliance with CBCR File Provision.
*In case of inaccurate information penalty of Rs. 5 Lacs

2. Kindly note that forms available on the Income Tax Website
Master File (Intimation by a
designated constituent entity,
resident in India, of an international
group, for the purposes of sub-
section (4) of section 92D of the
Income-tax Act, 1961)
Where there are more than one
constituent entities resident in India
of International Group.
File Form 3CEAB On or Before 1st
March, 2018 (Atleast 30 days prior
to filing of Master File in Form
3CEAA)
Intimation of being authorized by
international group to file form
3CEAA)
CBCR File (Intimation by a
constituent entity, resident in India,
of an international group, the
parent entity of which is not
resident in India, for the purposes
of sub-section (1) of section 286 of
the Income-tax Act, 1961)
Where there are constituent entity
resident in India of International
Group and consolidated group
revenue(FY 2015-16) > 5500
Crores.
File Form 3CEAC on or before 31st
January, 2018.
CBCR File (Intimation on behalf of
the international group for the
purposes of the proviso to sub-
section (4) of section 286 of the
Income-tax Act, 1961)
Where there are more than one
constituent entity and there is
systematic failure or lack ofTax
Information exchange agreement
with the country in which
International group is resident and
consolidated group revenue(FY
2015-16)> 5500 Crores.
File Form 3CEAE (Timeline not
PrescribedYet)

3. Step 1 - Login to the income tax portal (https://www.incometaxindiaefiling.gov.in) and login using the
Company credentials
Step 2 - Go to E-file Tab and select Prepare and submit online Form (other than ITR)
Step 3 - Select relevant Form and update the details online
Step 4 – Please note that relevant Form needs to be filed electronically using the digital signature
of the person authorized to sign tax return of respective Indian entities of the international group.
Once the Form is filled, the same would need to submitted using the DSC of the MD/director.
The steps to file Form 3CEAB/3CEAC/3CAEAE are as follows:-