Circular No. 3/2019 — Country-by-Country Reporting — master/local file
Date: 2019-01-01 Status: ACTIVE Category: International Taxation / DTAA Binding on Department: Yes (Section 119 / Section 400 IT Act 2025)
Summary
CbCR requirements. Constituent entities of international groups must maintain master file and local file.
Key Directions
- Parent entity with consolidated revenue exceeding threshold to file CbCR.
- Master file and local file mandatory.
- Filing in Form 3CEAC/3CEAD/3CEAE within prescribed timelines.
Applicability Under IT Act 2025
Saving Clause: Section 536 of IT Act 2025 saves circulars issued under the 1961 Act “so far as not inconsistent” with the new Act.
| Old Section (1961 Act) | New Section (2025 Act) | Consistent? |
|---|---|---|
| 286 | 175 | Yes |
Cross-References
Act Sections
Related Circulars
- None identified
Key Case Law (Circular Supremacy)
- To be populated — cases where this circular was cited/applied
Full Text
Full text to be added — see raw/circulars/ for PDF when available
Source
- Official: incometaxindia.gov.in/circulars