International tax for Foreign Companies in India — Overview
COUNTRY BY COUNTRY REPORTING - OECD
By Nagavarapu Bhavya Akshaya
Country-by-Country Reporting (CbCR) is a key component of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Action Plan 13, designed to enhance transparency in international taxation. It requires large multinational enterprise (MNE) groups to report annually on their global allocation of income, taxes paid, and other economic indicators across all jurisdictions where they operate.
The main purpose of CbCR is to:
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Provide tax authorities with a complete picture of the global activities of MNE groups.
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Enable detection of profit shifting and base erosion through analysis of income allocation and tax payments.
Reporting Requirements
CbCR requires the parent entity of an MNE group to submit a report containing information for each tax jurisdiction where the group operates, including:
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Revenue (from related and unrelated parties)
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Profit or loss before income tax
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Income tax paid and accrued
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Stated capital and accumulated earnings
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Number of employees
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Tangible assets other than cash
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List of entities and their main business activities
Structure of CbCR
The report generally comprises three key components:
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Master File – Provides an overview of the group’s global business, structure, and transfer pricing policies.
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Local File – Contains detailed information on material transactions of the local entity.
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CbCR Report – Country-wise summary of global income, taxes, and indicators of economic activity.
Filing Timeline and Authority (India)
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Filing Authority: Central Board of Direct Taxes (CBDT)
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Filing Due Date: Within 12 months from the end of the reporting accounting year.
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Forms Used:
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Form 3CEAC – Intimation of parent/alternate reporting entity.
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Form 3CEAD – Actual Country-by-Country Report.
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Form 3CEAE – Notification of designated entity details.
CbCR is shared automatically among tax authorities through exchange agreements between participating countries, enhancing global tax cooperation and preventing double reporting.
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About the Author – Nagavarapu Bhavya Akshaya
Nagavarapu Bhavya Akshaya is a CA Final and CMA Final student and an All India Rank holder (AIR 35). With a strong academic foundation in accounting, taxation, and corporate laws, she brings a structured and analytical perspective to complex financial and regulatory topics. Her work focuses on simplifying technical subjects for professionals and businesses, with a special interest in international taxation, corporate structuring, and compliance advisory.
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