Income Tax Rules, 2002

CHAPTER-VIA

DOCUMENTATION AND CO UNTRY-BY-COUNTRY REPORTING REQUIREMENTS PART-I PRELIMINARY

From: 2023-11-01 - To: 0000-00-00 27A. Application of this chapter:- (1) This chapter shall apply for the purposes of sub-sections (3) to (5) of section 108. (2) The purpose of this Chapter is to prescribe documents, information, files and reports which certain taxpayers are required to keep, maintain and furnish to the 2[Board and the] Commissioner under sub-sections (3) to (5) of section 108. (3) Nothing in this Chapter shall preclude a taxpayer accounting for income chargeable under the Ordinance, from- (a) maintaining any books of account, documents or records in addition to those prescribed in these rules; or (b) maintaining the books of account, documents or records in the manner prescribed keeping in view the head of the income of the taxpayer and, wherever applicable, the nature of the taxpayer’s business. (4) Definitions.- In this Chapter,- (a) “consolidated financial statements” mean the financial statements of an MNE group in which the assets, liabilities, income, expenses and cash flows of the ultimate parent entity and the constituent entities are presented as those of a single economic entity; (b) “competent authority agreement” means an agreement,- (i) that is between authorised representatives of those foreign jurisdictions that are parties to an international agreement with Pakistan; and (ii) that provides legal authority for the automatic exchange of country-by-country reports between the party jurisdictions; (c) “constituent entity” means,- (i) any separate entity of an MNE group that is included in the consolidated financial statements of the MNE group for financial reporting purposes or would be so included if equity interests in such business unit of an MNE group were to be traded on a stock exchange; (ii) any such entity that is excluded from the MNE group's consolidated financial statements solely on size or materiality grounds; and (iii) any permanent establishment of any separate entity of the MNE group included in sub-clauses (i) or (ii), provided the entity prepares a separate financial statement for such permanent establishment for financial reporting, regulatory, tax reporting or infernal management control purposes;…