Rule 10E: CbCR Reporting (Form 3CEB and 3CEBA)

Rule 10E of the Income-tax Rules, 1962 is the Indian rule that gives effect to the country-by-country reporting (CbCR) obligation under section 92F. The section sets the duty — the MNE group with consolidated revenue of ₹1,000 crore or more reports its allocation of income, tax and economic activity across jurisdictions — and the rule family sets the mechanics: who files in India, in what form, and how the report prepared abroad reaches the Indian authority.

What the provision says

In plain English, the rule family is one obligation expressed in four mechanics:

1. Rule 10E (the filing). Where the CbCR is prepared in India, it is filed by the relevant entity — the ultimate parent entity (UPE) resident in India, or the surrogate parent entity (SPE) where the UPE’s jurisdiction does not require the local filing, or the head office of the group in India. The rule’s core is the preparer role.
2. The Form 3CEB (the full CbCR). The per-jurisdiction report — the revenues (external and related-party), the profit before tax, the income tax paid and currently due, the employees, the tangible assets — filed with the return of income for the year.
3. The Form 3CEBA (the constituent’s statement). Where the CbCR is prepared outside India (the UPE abroad), the Indian constituent entity files its statement — the entity’s particulars feeding the group’s report — likewise with its return of income.
4. The information exchange. The channel by which the CbCR prepared in the parent’s jurisdiction reaches the Indian authority through the exchange of information between competent authorities — the automatic exchange (AEoI) that makes the CbCR a risk-assessment input for every jurisdiction in the group’s footprint.

The CbCR’s data is the third pillar of the BEPS Action 13 documentation set, alongside the Local File and the Master File — the same group data in three documents, which is why the reconciliation across them is the standing data-quality discipline.

The operative requirements

Element	Requirement
The duty (section 92F)	The MNE group with consolidated revenue of ₹1,000 crore or more reports, per jurisdiction, the allocation of income, tax and economic activity
The preparer (Rule 10E)	The UPE resident in India, else the SPE, else the head office in India — the hierarchy that decides who files the full CbCR where India prepares it
Form 3CEB (the full CbCR)	The per-jurisdiction report — the seven data items — filed with the return of income for the year
Form 3CEBA (the constituent’s statement)	The Indian constituent entity’s particulars, where the CbCR is prepared outside India — filed with the constituent’s return
The exchange	The CbCR prepared abroad reaches India through the exchange with the parent’s jurisdiction — the constituent’s 3CEBA and the exchanged full report carry the same data
The data	Per jurisdiction: the number of constituent entities, the external revenues, the related-party revenues, the profit before tax, the income tax paid, the income tax currently due, the employees, the tangible assets (net book value)
The threshold	The group’s consolidated revenue (the preceding financial year) — a yearly test, on the group, not the entity

Key excerpts (the provision’s core, framed)

• The preparer hierarchy is the rule’s core: the CbCR prepared in India is filed by the UPE resident in India, the SPE, or the head office of the group in India — the one group-level document with a named Indian filer.
• The constituent’s role is the statement, not the report: where the preparation is abroad, the Indian entity files the 3CEBA — its own jurisdiction’s row plus the required particulars — while the full CbCR travels by exchange.
• The threshold is on the group’s consolidated revenue (the ₹1,000 crore test), the same threshold family as the Master File — the group that triggers the CbCR almost always triggers the Master File too, and the two share their underlying segment and country data.

What it means in practice

• Three documents, one data set. The CbCR rows, the 3CEBA particulars and the Local File / Master File country and segment breakdowns are the same numbers in three documents. The row that differs across the three is the scrutiny trigger — the reconciliation is the discipline, documented and repeatable. See the CbCR guide for the data-quality treatment.
• The exchange means the foreign-prepared CbCR reaches India anyway. The 3CEBA is the Indian entity’s obligation; the full report arrives through the competent-authority channel regardless. The practical exposure is the data quality of the Indian rows — the entity’s numbers reconciling to the statutory accounts and to the group’s consolidation.
• The CbCR is the risk-assessment input. It is the document the authorities use to find the file: a group row with an unexplained margin, an India row that does not match the Local File’s economics, a PE row with profit but no substance — each opens the examination. The prevention is the same reconciliation that the compliance calendar schedules.
• The filing rides the return. Both forms are filed with the return of income for the year — the Form 3CEB glossary and the Form 3CEBA glossary carry the form mechanics, and the Rule 10E glossary the filing-chain summary.

Related docs

• Rule 10E — the glossary entry
• CbCR guide — thresholds, filing, data quality
• Form 3CEB · Form 3CEBA
• Section 92F — the documentation thresholds