Master file reporting requires multinational groups to file comprehensive group and transfer pricing documentation under section 92D. Report obligation under sub section (4) of section 92D requires submission of Master File (Form 3CEAA) containing: identification of the assessee and international group; list of constituent entities and addresses; legal status and ownership chart; written business description covering nature of business, profit drivers, supply chains, inter group services and transfer pricing policies; functions assets risks analysis for material contributors; intangible property strategy and ownership; inter company financing arrangements and policies; consolidated financial statements; and a list of unilateral APAs and tax rulings, with a verification declaration.
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Master file reporting requires multinational groups to file comprehensive group and transfer pricing documentation under section 92D.
Report obligation under sub section (4) of section 92D requires submission of Master File (Form 3CEAA) containing: identification of the assessee and international group; list of constituent entities and addresses; legal status and ownership chart; written business description covering nature of business, profit drivers, supply chains, inter group services and transfer pricing policies; functions assets risks analysis for material contributors; intangible property strategy and ownership; inter company financing arrangements and policies; consolidated financial statements; and a list of unilateral APAs and tax rulings, with a verification declaration.
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