Master file disclosure requirements for constituent entities cover group structure, intangibles, financing, and transfer pricing. Form No. 56 prescribes the master file information and supporting documents to be furnished by a person who is a constituent entity under section 171(4). It requires particulars of the reporting person, the accounting year, and details of the international group, including constituent entities operating in India and all constituent entities of the group, together with information on legal status and involvement with intangible property. The annexures seek disclosures on group ownership, business operations, intangible property, financing arrangements, transfer pricing policies, consolidated financial statements, and existing advance pricing agreements and tax rulings.
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Provisions expressly mentioned in the judgment/order text.
Master file disclosure requirements for constituent entities cover group structure, intangibles, financing, and transfer pricing.
Form No. 56 prescribes the master file information and supporting documents to be furnished by a person who is a constituent entity under section 171(4). It requires particulars of the reporting person, the accounting year, and details of the international group, including constituent entities operating in India and all constituent entities of the group, together with information on legal status and involvement with intangible property. The annexures seek disclosures on group ownership, business operations, intangible property, financing arrangements, transfer pricing policies, consolidated financial statements, and existing advance pricing agreements and tax rulings.
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