The CBDT on 5th April, 2021 has notified changes in Rule 10DA & Rule 10DB (referred to herein as the “Rule”) effective from 1st April, 2021.
The threshold limit for filing CbCR report under Rule 10DB has been increased from ₹5500 crore to ₹6400 crore to factor in the prevailing exchange rates, as OECD provides Euro 750 million threshold.
The Board has also clarified that any entity can be designated to file a Master File in India on behalf of its international group, and such entity is not restricted to an Indian entity only. Thus, even a foreign entity can be treated as a constituent entity for filing under Rule 10DA andthe threshold for applicability of filing Master file shall be benchmarked accordingly.
