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India Issues Circular Requiring CbC Report Local Filing for U.S. MNEs with Short Extension — Orbitax Tax News & Alerts

India's Central Board of Direct Taxes has issued Circular 7/2019 of 8 April 2019, which provides that constituent entities of U.S. MNEs are required to submit Country-by-Country (CbC) reports in India by 30 April 2019. The circular notes that although a CbC exchange agreement between India and the U.S. was signed on 27 March 2019, the procedures required for its activation have not yet been completed and therefore local filing is required. Previously, an extension to 31 March 2019 was provided for reporting accounting (fiscal) years ending up to 28 February 2018. Now, an extension is provided to 30 April 2019 for reporting accounting years ending up to 29 April 2018.

Note - At the time of writing, the IRS CbC Reporting Jurisdiction Status Table still indicated that "Local filing will not be required in India". It is expected that this will be updated.