The Central Board of Direct Taxes (CBDT) has extended the due date for furnishing of Country-by-Country Report under Section 286(4) of Income Tax Act, 1961.
In keeping with India’s commitment to implement the Recommendations of the 2015 Final Report on Action 13, titled “Transfer Pricing Documentation and Country-by-Country Reporting”, identified under the OECD Base Erosion and Profit Shifting (BEPS) Project, Section 286 of the Income-tax Act, 1961 was inserted vide Finance Act, 2016, which provides for furnishing of a Country-by-Country (CbC) Report in respect of an International Group.
The CbC Report is to be furnished by the ultimate parent entity of an International Group in the country or territory of its residents.
Sub-section (4) of Section 286 specifies situations in which the said report shall be furnished in India by the constituent entity of an international group, resident in India, namely, those in which there is failure to obtain CbC Report on account of the parent entity being resident of a country or territory with which India does not have an agreement providing for exchange of CbC reports or where there has been a systemic failure of the country or territory and the same has been intimated to such constituent entity.
