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        GOI signatory of Multilateral Competent Authority Agreement for automatic exchange of Country-by-Country Reporting (CbC MCAA) pertaining to tax cooperation to enable automatic sharing of Country-by-Country information

        March 18, 2017

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        The Government is a signatory of Multilateral Competent Authority Agreement for automatic exchange of Country-by-Country Reporting (CbC MCAA) pertaining to tax cooperation to enable automatic sharing of Country-by-Country information

        The Multilateral Competent Authority Agreement (MCAA) for automatic exchange of Country-by-Country (CbC) Reports has been developed by the Organisation of Economic Cooperation and Development (OECD) to facilitate amongst countries the automatic exchange of CbC Reports filed by Multinational Enterprises (MNEs). The MCAA has been developed to take forward the commitment of G-20 and OECD member countries, under the Base Erosion and Profit Shifting (BEPS) Project, to usher in a completely new Transfer Pricing documentation regime. The CbC Report is expected to provide countries with vital information to help them assess transfer pricing risks and select cases for audit. Detailed audit of such high-risk cases would help prevent profit shifting by MNEs through the transfer pricing mechanism. India signed the MCAA for CbC on 12/05/2016 and shall exchange CbC Reports from 2018.

        As per the information available, 57 countries have signed the MCAA for CbC till date. Some of the recent signatories are Russian Federation, Mauritius, Indonesia and Gabon.

        This was stated by Shri Santosh Kumar Gangwar, Minister of State in the Ministry of Finance in written reply to a question in Lok Sabha.

        Automatic exchange of Country-by-Country reports enhances tax transparency and targets transfer pricing risk under BEPS. India has executed the Multilateral Competent Authority Agreement (MCAA) to enable automatic exchange of Country-by-Country Reports filed by Multinational Enterprises under the OECD/G 20 BEPS framework, providing tax authorities with consolidated information to identify transfer pricing and profit shifting risks and to prioritise audits; India signed the MCAA in May 2016 and will begin exchanges from 2018.
                          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.

                                Automatic exchange of Country-by-Country reports enhances tax transparency and targets transfer pricing risk under BEPS.

                                India has executed the Multilateral Competent Authority Agreement (MCAA) to enable automatic exchange of Country-by-Country Reports filed by Multinational Enterprises under the OECD/G 20 BEPS framework, providing tax authorities with consolidated information to identify transfer pricing and profit shifting risks and to prioritise audits; India signed the MCAA in May 2016 and will begin exchanges from 2018.





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                                ActsIncome Tax
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