CA Final · Direct Tax Laws & International Taxation · Latest Developments in International Taxation

Kaveri Tech Pvt Ltd, an Indian company, belongs to a foreign MNE group. Its constituent entities hold a Master File and Country-by-Country reporting obligations apply. The group's consolidated revenue in the preceding accounting year was well above the CbC threshold of EUR 750 million (in the parent's jurisdiction). Which statement about the Indian CbCR regime is correct?

An Indian constituent entity of a foreign-parented group may have to furnish the CbC report if the parent is not required to file, the parent's jurisdiction lacks an exchange arrangement or has systemic failure, and no alternate reporting entity is designated. It applies only to large groups and does not replace Form 3CEB.

1. ACbC report is filed by every Indian company regardless of group size
2. BAn Indian constituent entity of a foreign group may need to furnish the report if the parent is not required to file, or the parent's jurisdiction has no exchange arrangement, and the group designates no alternate reporting entityCorrect
3. CCbC report replaces the Transfer Pricing accountant's report
4. DCbC reporting applies only to Indian parent companies of resident groups