Country-by-Country Reporting (CbCR) Compliance under Section 286 – Due Date & Key Requirements

Multinational groups with operations in India must comply with Country-by-Country Reporting (CbCR) obligations under Section 286 of the Income-tax Act, 1961. This ensures transparency in global income allocation and taxes paid.

Applicability and Reporting Entities

CbCR applies to constituent entities resident in India that are part of an international group where:

• The parent entity is not required to file CbCR in its jurisdiction, or
• India has no agreement for exchange of such reports, or
• There is a failure in information exchange

Entities required to file include:

• Parent Entity resident in India
• Alternate Reporting Entity (ARE)
• Other constituent entities, under specified conditions

Reporting Period and Due Date

For the reporting accounting year April 1, 2024 to March 31, 2025, the due date for filing Form 3CEAD is:

• On or before March 31, 2026 (i.e., 12 months from the end of the reporting year)

Key Compliance Points

• Maintain accurate group-level financial and tax data
• File intimation in Form 3CEAC/3CEAE, if applicable
• Ensure consistency with transfer pricing documentation
• Penalties apply for delayed or incorrect filing

Relevant Legal References

• Section 286 of the Income-tax Act, 1961
• Rule 10DB of the Income-tax Rules, 1962
• CBDT Notification No. 88/2017 dated 31 October 2017

Conclusion

Timely and accurate CbCR compliance is critical to avoid penalties and scrutiny. Businesses should proactively review their reporting obligations.

For expert guidance on this topic, contact your tax professional today.