Country By Country Reporting – Transfer Pricing

Navigate Compliance with Ease: TPVerse’s Country by Country Reporting Transfer Pricing Services

TPverse is a global corporation that specializes in transfer pricing including Cbc report transfer pricing, with a team of highly qualified individuals from all over the world. TPVerse is well-versed in international transfer pricing regulations and can help with the preparation of comprehensive Cbc reporting.

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BEPS Action Plan 13 and CbCR Requirements

The OECD i.e., the Organisation for Economic Co-operation and Development recommended a three-tier documentation as part of the Base Erosion and Profit Shifting (BEPS) package – Action Plan 13. The three-tier documentation includes the following:

  1. Country by Country Report (CbCR)
  2. Master File
  3. Local File

Following this, India introduced the provisions relating to Country-by-Country Reporting under the Income Tax Act, 1961 through the Finance Act 2016. India already had provisions whereby the local entities of the Multinational Enterprises (MNEs) are required to maintain the transfer pricing documentation. The additional responsibilities placed upon them are for the master file and country-by-country report.

The Significance of BEPS Action Plan 13

One of the four BEPS minimum standards is the Country-by-Country reporting requirements that are outlined in the 2015 Action 13 Report. Peer review is applied to each of the four BEPS minimum standards to guarantee correct and timely implementation and protect the level playing field. Each and every member of the Inclusive Framework on BEPS pledges to apply the Action 13 minimum standard and to take an equal part in the peer review process.

Country By Country Reporting Applicability

A country-by-country (CbC) report containing aggregate data on the worldwide distribution of income, profit, taxes paid, and economic activity among the tax countries in which it operates must be prepared by all big multinational enterprises (MNEs) in accordance with BEPS Action 13. 

The tax administrations in these jurisdictions receive access to this CbC reporting for use in BEPS risk assessments and high level transfer pricing analyses. This database gives MNEs and tax administrations a summary of which members of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) have implemented a CbC reporting duty, as well as some basic information about when and how these duties function.

CbCR Reporting in India – Section 286 of the Income Tax Act, 1961

CbCR reporting in India is governed by Section 286 of the Income Tax Act, 1961. As per the income tax law in India, the constituent entities of MNE Groups are required to undertake CbCR compliances if they have a consolidated revenue of Rs. 64 billion (i.e., € 750 million as per the international standards)

Therefore, a parent entity or an alternate reporting entity (AER) of an international group shall be required to prepare and furnish the Country-by-Country report within 12 months after the reporting accounting year ends if it is resident in India. In other cases (i.e., where the parent entity or alternate reporting entity is not resident in India), the constituent entity that is resident in India shall notify the details of the parent entity or AER to the prescribed income tax authorities that is filing the CbCR. This information will help the government in getting information and access to the CbCR report through the exchange of information with other countries.

Essential Data Points in CbCR

In CbCR, the group needs to provide the details of revenue generated, profits earned, retained earnings, taxes paid, etc. for each of the entities in the MNE group regardless of the country in which the multinational enterprise is located. This shows the information of each entity in the group and gives an understanding of the transfer pricing policy followed by the group as a whole.

TPverse’s Expertise in CbC Report Preparation and Compliance

Their team comprises highly skilled and experienced Transfer Pricing professionals who can manage projects needing exact delivery times, superior quality, and personalized attention. Their main assets are their professionalism, discipline, and knowledge.

At TPverse, the team of transfer pricing specialists delivers thoughtful and innovative transfer pricing strategies to maximize company profits and minimize audit risk. It can help with your unique transfer pricing challenges and compliance with OECD regulations.

By providing a broad range of CbCR transfer pricing paperwork and transfer pricing services that assist in the creation of effective cross-border tax structures, we at TPVerse bring value.

TPverse’s transfer pricing policy design experts, who have appropriate connections and a professional network in significant international tax jurisdictions, enable them to provide Indian multinationals with efficient outbound and inbound CbCR transfer pricing design, documentation, and dispute resolution services.

Expertise in CbCR Preparation

With TPVerse’s in-depth understanding of international transfer pricing legislation, they can help with the preparation of comprehensive country-by-country reports that adhere to national laws. 

Prepare CBC reporting statements

The CbC report must include specific financial information about the Group broken down by tax jurisdiction using a template that is defined. This information is shown below. A list of member entities broken down by country of residency, together with a description of their activities, must also be provided. 

The term “Constituent Entity” refers to any distinct business unit inside the group, encompassing corporations and permanent establishments that prepare independent financial statements whether or not material and consolidated in the Financials of the Parent.

Get in Touch With TPverse Expert

For the best local transfer price products and services, email info@TPverse.in.

Partnering With TPverse for CbCR Compliance Excellence

The main objective at TPVerse is to give their customers the best transfer pricing products and services possible. Their constant goals are to increase the size of their team of professionals, upgrade their technological setup, and broaden the scope of offerings in order for you to use them to receive the greatest Transfer Pricing Services available.

The most cutting-edge and modern CbCR transfer pricing options will be provided to you. Their goals include reaching new markets, staying up to date on industry innovations, and maintaining their position as the world’s top supplier of transfer pricing solutions.

 All of this will guarantee that services are always compliant with applicable transfer pricing requirements and provide you with the most complete and efficient transfer pricing solutions available. Get Seamless Compliance Solutions with TPVerse.

FAQ’s on CBC Reporting Transfer Pricing

A Country-by-Country Report (CbCR) is a requirement under transfer pricing regulations for multinational enterprises (MNEs) to provide detailed information on their global allocation of income, taxes paid, and certain indicators of the location of economic activity within the jurisdictions in which they operate.
The CbCR is crucial for tax authorities to assess transfer pricing risks and ensure that multinational companies are reporting their income and taxes accurately across different jurisdictions. It helps prevent tax evasion and profit shifting by providing transparency into the allocation of profits and taxes.
MNEs with consolidated group revenue exceeding a certain threshold (€750 million or INR 64 Billion) are required to file a CbCR in accordance with the regulations of the jurisdictions in which they operate.
A CbCR typically includes information on the global allocation of income, taxes paid, and certain economic indicators such as the number of employees, tangible assets, and sales in each jurisdiction where the MNE operates