Income Tax Rules, 2002

CHAPTER-VIA

DOCUMENTATION AND CO UNTRY-BY-COUNTRY REPORTING REQUIREMENTS PART-III DOCUMENTATION REQUIREMENTS

From: 2023-11-01 - To: 0000-00-00 27N. Local file referred to in rule 27M, shall include - (a) local entity structure including its management structure of the local entity, a local organization chart and a description of the individuals to whom local management reports and the country or countries in which such individuals maintain their principal offices; (b) a detailed description of the business and business strategy pursued by the local entity including an indication whether the local entity has been involved in or affected by business restructurings or intangibles transfers in the present or immediately past year and an explanation of those aspects of such transactions affecting the local entity; (c) key competitors; (d) information for each category of controlled transactions in which the taxpayer is involved, including - (i) a description of all the controlled transactions (e.g. procurement of manufacturing services, purchase of goods, provision of services, loans, financial and performance guarantees, licences of intangibles, etc.) and the context in which such transactions take place; (ii) the amount of intra-group payments and receipts for each category of controlled transactions involving the local entity (i.e. payments and receipts for products, services, royalties, interest, etc.) broken down by tax jurisdiction of the foreign payer or recipient; (iii) an identification of associated enterprises involved in each category of controlled transactions and the relationship amongst them; (iv) detailed list of all inter-company agreements and copies of all such agreements concluded by the taxpayer; (v) a detailed comparability and functional analysis of the taxpayer and relevant…