In the Fiscal Budget of 2016, India had committed to robust TP documentation by agreeing to introduce Master File and Country by Country (‘CbCR’) Report requirements in line with OECD’s Base Erosion and Profit Shifting (BEPS’) project recommendations. In this regard, a draft set of rules were opened for public comments and based on inputs received, the final set of rules have been introduced through a formal notification on October 31, 2017.
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