Form 3CEBA: The Constituent Entity’s CbCR Statement
Form 3CEBA defined: the constituent entity’s statement in the CbCR regime — the Indian entity’s share of the group’s country-by-country report.
Definition
Form 3CEBA is the constituent entity’s statement in the CbCR (country-by-country reporting) regime — the Indian constituent entity’s share of the group’s country-by-country report, filed where the group’s consolidated revenue crosses the threshold (the Indian ₹1,000 crore, the BEPS Action 13 tier). It is the Rule 10DB context in the India convention: the CbCR itself (the per-jurisdiction revenue, profit, tax, employees, tangible assets) is prepared at the group level (the UPE, or the designated group member), and the 3CEBA is the constituent entity’s statement — the entity’s particulars that feed the group’s CbCR, the entity’s filing where the regime requires it.
| The element | The content |
|---|---|
| The CbCR (the group level) | The per-jurisdiction allocation — the revenue, the profit before tax, the income tax paid / accrued, the number of employees, the tangible assets — per jurisdiction, for the in-scope group (the consolidated revenue above the threshold) |
| The 3CEBA (the entity level) | The constituent entity’s statement — the Indian entity’s particulars (the entity’s revenue, profit, tax, employees, assets, in the CbCR’s format) — the entity’s share of the group’s CbCR |
| The filer | The constituent entity (the Indian entity, where the regime requires the entity-level statement) — with the return, per the compliance calendar |
| The threshold | The group’s consolidated revenue above the ₹1,000 crore (the CbCR tier, the Rule 10DB) — the group in scope, the constituent entities’ statements feeding it |
The working read (the CbCR guide and the jurisdiction comparison): the CbCR is the group-level allocation (the per-jurisdiction totals, the UPE’s preparation), and the 3CEBA is the entity-level statement (the Indian entity’s particulars, the entity’s filing). The distinction from the Form 3CEB (the CA’s report on the transactions, the s.92E, the entity-level TP report): the 3CEB is the TP documentation report (the transactions, the method, the position), the 3CEBA is the CbCR statement (the jurisdictional allocation, the group’s per-country totals) — the two forms, the two subjects, the same filing day (the return). The CbCR’s data-quality risks (the CbCR guide) are the 3CEBA’s risks — the entity’s particulars that feed the group’s report, the reconciliation the guide carries.
Example
The MNE group (the consolidated revenue ₹5,000 cr, above the ₹1,000 cr CbCR threshold): the UPE prepares the CbCR (the per-jurisdiction revenue, profit, tax, employees, tangible assets). The Indian constituent entity files the Form 3CEBA — the entity’s statement (the entity’s revenue, profit before tax, tax paid, employees, tangible assets, in the CbCR’s format) — with the return, per the compliance calendar. The 3CEBA feeds the group’s CbCR (the Indian column, the entity’s particulars); the group’s CbCR is exchanged (the competent authorities, the CbCR guide exchange mechanics). The entity’s 3CEBA and the entity’s Form 3CEB (the CA’s TP report) ride the same filing day — the two forms, the two subjects, the return’s annexures.
See also
FAQ
Form 3CEBA or Form 3CEB — which is which? The 3CEB is the CA’s report on the international transactions (the s.92E report, the TP documentation’s transactions block, the s.271BA penalty on the miss). The 3CEBA is the constituent entity’s CbCR statement (the Rule 10DB context, the jurisdictional allocation, the group’s per-country totals). The two forms, the two subjects (the transactions vs the allocation), the same filing day (the return) — the compliance calendar has the rows separate.
Who prepares the CbCR — the UPE or the constituent entity? The UPE (prepared in the UPE’s jurisdiction) or the designated group member (where the UPE’s jurisdiction does not exchange, the designation) — the group-level preparation. The constituent entity (the Indian entity) files the 3CEBA (the entity’s statement, the entity’s particulars) — the entity’s share feeding the group’s report. The group prepares, the entity states, the competent authorities exchange — the CbCR guide has the mechanics.
What data-quality risks does the 3CEBA carry? The entity’s particulars (the revenue, the profit, the tax, the employees, the tangible assets) that feed the group’s CbCR — the CbCR guide’s data-quality risks: the entity’s numbers reconciling to the statutory accounts, the jurisdictional allocation consistent with the Local File and the Master File, the per-country totals matching the group’s consolidation. The 3CEBA is the entity’s share of the CbCR’s data quality — the reconciliation the guide carries, at the entity level.
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Related docs
CbCR: Country-by-Country Reporting Defined and Explained
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Form 3CEB defined: the chartered accountant’s report on the international transactions, filed with the return — the section 92E report and the section 271BA penalty.
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