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Master file and country-by-country reporting require detailed transfer pricing, intangibles, and financing disclosures for multinational groups. The rules require constituent entities of international groups to maintain a prescribed Master File when consolidated group revenue and specified international transaction thresholds are exceeded, detailing group structure, business description, supply chains, transfer pricing policies, intangibles, financing arrangements, consolidated financial statements and tax rulings, retained for eight years and filed in Form 3CEAA. They also require Country-by-Country reporting where consolidated group revenue meets a higher threshold, with intimation and filing obligations in Forms 3CEAC/3CEAD and designation procedures for Indian resident entities, plus electronic filing and exchange-rate rules.
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Provisions expressly mentioned in the judgment/order text.
Master file and country-by-country reporting require detailed transfer pricing, intangibles, and financing disclosures for multinational groups.
The rules require constituent entities of international groups to maintain a prescribed Master File when consolidated group revenue and specified international transaction thresholds are exceeded, detailing group structure, business description, supply chains, transfer pricing policies, intangibles, financing arrangements, consolidated financial statements and tax rulings, retained for eight years and filed in Form 3CEAA. They also require Country-by-Country reporting where consolidated group revenue meets a higher threshold, with intimation and filing obligations in Forms 3CEAC/3CEAD and designation procedures for Indian resident entities, plus electronic filing and exchange-rate rules.
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