India and the United States on Wednesday signed an agreement for exchange of country-by-country (CbC) reports, a move that will enable enhanced level of risk assessment by both tax administrations.
The agreement was signed by P C Mody, Chairman of the Central Board of Direct Taxes, and Kenneth I. Juster, US Ambassador to India.
Multinational enterprise groups having global consolidated revenue of 750 million euros or more (or a local currency equivalent) in a year are required to file CbC reports in their parent entity’s jurisdiction. In Indian rules, the rupee equivalent of 750 million euros has been prescribed as Rs 5,500 crore.
A CbC report has aggregated country-by-country information relating to global allocation of income, taxes paid and certain other indicators of an MNE group.
It also contains a list of all the constituent entities of a multinational enterprise group operating in a particular jurisdiction and the nature of the main business activity of each such constituent entity.
India has already signed the Multilateral Competent Authority Agreement for exchange of CbC reports with 62 jurisdictions.