Transfer Pricing Compliance Details for FY 2017-18
1. Accountant’s Report in Form 3CEB
– Due date is 30 November. To be filed even if there is single rupee international transaction with associated enterprise.
2. Transfer Pricing Documentation
-To be prepared and maintained as per Rule 10D by 30 November 2018. To be maintained if the value of international transaction during FY 2017-18 exceeds Rs. 1 Crore.
3. Country by Country Reporting (CbCR)
• Form 3CEAC (Notification)-
Every Indian constituent entity of a foreign IG to file the CbC report notification in India. Due date- Two months prior to the due date for filing the CbC report
• Form 3CEAD (CbCR)– To be filed by
(i) Indian headquartered IG
(ii) Indian entity of foreign IG designated as alternate reporting entity
(iii) Indian constituent entity of foreign IG required to submit CbC report in India under the specified circumstances
Due date – 31March 2019. To be filed if the consolidated group revenue exceeds Rs. 5500 Crores in preceding year.
•3CEAE– Foreign IG required to file CbC report in India under specified circumstances and having multiple constituent entities resident in India. No timelines prescribed
4. Master File– Form 3CEAA (Due date 30 November 2018)
• Part A of Form 3CEAA
– Every constituent entity of an IG having international transactions/specified domestic transactions. No threshold applies.
• Part B of Form No. 3CEAA
– Every constituent entity of an IG meeting the prescribed threshold limit. Threshold is as under:
(i) For the accounting year, consolidated group revenue > INR 500 Cores;
(ii) The aggregate value of international transactions, as per books of accounts, for the accounting year :
‒ exceeds INR 50 Cores ,
‒ In relation to intangibles exceeds INR 10 Crores
• Form 3CEAB–
Intimation of designated Indian constituent entity of International Group for filing master file. Due Date -30 November prior to due date of filing Master File.
All prescribed Forms (Form Nos 3CEAA, 3CEAB, 3CEAC, 3CEAD and 3CEAE) have to signed by the person competent to verify the return of income. Stringent penalties for non-compliance of above provisions. Feel free to raise any queries