Introduction
Country-by-Country Reporting (CbCR), introduced by the OECD under BEPS Action 13, mandates large MNEs to disclose global revenue, profits, taxes paid, and economic activity by jurisdiction.
Who Must File
MNE groups with consolidated revenue > EUR 750 million.
Typically filed by the parent entity and shared with tax authorities via automatic exchange.
Key Components of CbCR
Revenue, profit/loss before tax, income tax paid/accrued
Number of employees, tangible assets, stated capital
List of entities and business activities
India’s Framework
Applicable to Indian-headquartered MNEs and foreign MNEs with Indian subsidiaries
Reporting required under Rule 10DB and Form 3CEAC/3CEAD
Impact on TP Risk Assessment
Enables tax authorities to conduct high-level risk analysis
Used to select cases for detailed TP audits
Conclusion
CbCR is a powerful transparency tool. While it does not replace traditional TP documentation, it reinforces the need for coherence between business substance, profit allocation, and tax disclosures.
