Direct Tax Alert
Transfer Pricing, Master Filing & CbCR Compliances – FY 2021-22 -Timelines & Penalties
September 10, 2022
| 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 |
| 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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