Country-by-Country Reporting requirement establishes filing obligations, thresholds and prescribed forms for international groups under income tax law. Country-by-Country reporting obligations require constituent or parent entities of international groups to file a CbCR with the income-tax return for the relevant accounting year once consolidated group revenue meets the prescribed threshold. A separate Master File obligation is triggered by a consolidated revenue threshold and specified international-transaction value thresholds; Part A of the Master File must be completed by each constituent entity, though an international group with multiple local constituents may designate one entity to file Part A on its behalf. Distinct prescribed forms are provided for the Master File and the CbCR.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Country-by-Country Reporting requirement establishes filing obligations, thresholds and prescribed forms for international groups under income tax law.
Country-by-Country reporting obligations require constituent or parent entities of international groups to file a CbCR with the income-tax return for the relevant accounting year once consolidated group revenue meets the prescribed threshold. A separate Master File obligation is triggered by a consolidated revenue threshold and specified international-transaction value thresholds; Part A of the Master File must be completed by each constituent entity, though an international group with multiple local constituents may designate one entity to file Part A on its behalf. Distinct prescribed forms are provided for the Master File and the CbCR.
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