TaxTMI 
TaxTMI 
Definitions
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....h day of May, 2016, being date that is later of the date of notification to the Coordinating Body Secretariat and the date on which the Convention has entered into force, in accordance with paragraph 2 of Section 8 of the said Agreement; Now, therefore, in exercise of the powers conferred by clause (b) of sub-section (9) of section 286 of the Income-tax Act, 1961 (43 of 1961), the Central Government hereby notifies the said Agreement, as set out in the annexure hereto, and all the provision of the said Agreement shall be given effect to in the Union of India in accordance with paragraph (2) of Section 8 of the said Agreement. [Notification No. 75/2017/F.No. 500/15/2015-APA-I] PRAGYA S. SAKSENA, Jt. Secy. (FT & TR-I) ANNEXURE MULTILATE....
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....eas, the laws of the respective Jurisdictions require or are expected to require the Reporting Entity of an MNE Group to annually file a CbC Report; Whereas, the CbC Report is intended to be part of a three-tiered structure, along with a global master file and a local file, which together represent a standardised approach to transfer pricing documentation which will provide tax administrations with relevant and reliable information to perform an efficient and robust transfer pricing risk assessment analysis; Whereas, Chapter III of the Convention authorises the exchange of information for tax purposes, including the exchange of information on an automatic basis, and allows the competent authorities of the Jurisdictions to agree on the sco....
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.... of Section 6 of this Agreement; Whereas mutual agreement procedures, for instance on the basis of a double tax convention concluded between the jurisdictions of the Competent Authorities, remain applicable in cases where the CbC Report has been exchanged on the basis of this Agreement; Whereas, the Competent Authorities of the jurisdictions intend to conclude this Agreement, without prejudice to national legislative procedures (if any), and subject to the confidentiality and other protections provided for in the Convention, including the provisions limiting the use of the information exchanged thereunder; Now, therefore, the Competent Authorities have agreed as follows: SECTION 1 Definitions 1. For the purposes of this Agreement, th....
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....ar, as reflected in its consolidated financial statements for such preceding fiscal year, is below the threshold defined in domestic law by the Jurisdiction and being consistent with the 2015 Report, as may be amended following the 2020 review contemplated therein; f. the term "Constituent Entity" means (i) any separate business unit of an MNE Group that is included in the consolidated financial statements for financial reporting purposes, or would be so included if equity interests in such business unit of an MNE Group were traded on a public securities exchange (ii) any separate business unit that is excluded from the MNE Group's consolidated financial statements solely on size or materiality grounds and (iii) any permanent establishmen....