Q : Rule 10 DA(1) requires the description of FAR analysis for all Constituent Entities (CEs) contributing at least 10 percent of the revenues or assets or profits of the group in the Master File. Should the basis of including or excluding a CE in the Master File be justified? If so, how detailed a justification should be provided?


Kunj Vaidya (Partner and Leader, Transfer Pricing, PwC India)

There is no formal requirement to disclose the basis of inclusion or exclusion of a constituent entity as part of the working. However, it should be prudent to prepare a detailed working file to justify the inclusion or exclusion of a constituent entity.

The above responses to the questions has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. PricewaterhouseCoopers Private Ltd, its members, employees and agents do not accept or assume any liability, responsibility or duty of care for any consequences faced by anyone who have chosen to rely on the information contained in this publication or for any decision based on it. 

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