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    Transfer Pricing, Master Filing & CbCR Compliances – FY 2021-22 -Timelines & Penalties

    September 10, 2022

    Due Dates of Compliances for the FY 2021-22
    S. No. Particulars Due Dates
    1. Transfer Pricing Certification, i.e. Filing of Form 3CEB [Section 92E] 31st October, 2022
    2. Master Filing Compliance, i.e. filing of Form 3CEAA [Section 92D(4)] 30th November, 2022
    3. Country-by-Country Reporting (CbCR) Compliance, i.e. filing of intimation in Form 3CEAC by a resident constituent entity of an international group [Section 286(1) read with Rule 10DB(2)] 31st January, 2023
    4. Country-by-Country Reporting (CbCR) Compliance, i.e. filing of Form 3CEAD [Section 286(2) read with Rule 10DB(3)] 31st March, 2023
    Penalties for Non-Compliances  
    S. No. Particulars Penalties
    1. Transfer Pricing Certification, i.e. non-filing of Form 3CEB [Section 92E] Rs. 1,00,000/- [Section 271BA]
    2. Transfer Pricing Documentation, i.e. failure to furnish the Transfer Pricing Study Report [Section 92D(1)] 2 % of the value of each international transaction [Section 271AA(1)]
    3. Master Filing Compliance, i.e. non-filing of Form 3CEAA [Section 92D(4)] Rs. 5,00,000/- [Section 271AA(2)]
    4. Country-by-Country Reporting (CbCR) Compliance, i.e. failure to furnish the report in Form 3CEAD [Section 286(2)] Rs. 5,000/- per day (if the period of failure does not exceed 1 month); and Rs. 15,000/- per day (for which the failure continues beyond the period of 1 month) [Section 271GB(1)]
     

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