What is CBCR Threetiered standardised approach to TP

What is CBCR ? • Three-tiered standardised approach to TP documentation for MNCs with turnover of € 750 million or more • CBCR– bird eye view of value creation & tax position (to be filed at parent level) • Master File - Contains high level information about MNC’s business such as supply chain, operating entities, transfer pricing policies, intangible property, financing, APAs and rulings (to be filed locally) • Local File - Contains information on all material intercompany transactions, intragroup payments and receipts for each category of controlled transactions, and copies of relevant rulings (to be filed locally) • To be used by tax administrations in evaluating other BEPS related risks • Information to be shared via automatic exchange of information framework

CBCR Template Revenues Tax juris -diction Unrelate Related d party Total Tangible Profit assets (loss) Cash Tax Current Accumul other Paid Stated before CIT and year tax than ated capital accrual earnings cash and income WHT tax cash equi -valents No of employees 2

Tax jurisdiction Constitu entities resident in the tax jurisdiction Tax jurisdiction of organization or incorporatio n if different from tax jurisdiction of residence 1. 2. 3. Other Dormant Holding shares or other equity instruments Insurance Regulated financial services Internal group finance Provision of services to unrelated parties Admin. , Mgmt or support services Sales, marketing or distri. Mfg or production Purchasing or procurement Holding or managing IP R & D Cb. C reporting template Main business activity(ies)

India and BEPS • Finance Bill 2016 proposes Sec 286 which seeks to provide CBCR and Master File reporting • Applicable from FY 2016 -17 • Indian MNCs (satisfying revenue threshold) • Indian subsidiaries (being constituent entities) • Detailed rules to be notified • Penalty • Rs 5000 to Rs 50, 000 per day for non-furnishing of CBCR or required information • Rs 500, 000 for finishing inaccurate particulars or non-furnishing of master file data