Eighteen months after the adoption of country-by-country reporting (CbCR) legislation for multinationals, the CBDT has finally drafted rules for compliance and disclosure for MNCs operating in India. The proposed rules spell out how and in which form the multinationals would have to comply with the maintaining and furnishing of transfer pricing documentation in the Master File (MF) and the country-by-country report. The rules have been placed on the CBDT website for public comments. The CbCR requirements are largely in line with the Base Erosion and Profit Shifting (BEPS) Action Plan-13, with significant penalties in case of violations of the provisions. It may be recalled that BEPS measures were endorsed by G20 leaders in November 2015. The BEPS project had set out 15 key actions (of which CbCR is one, under Action Plan 13) to reform the international tax framework and ensure that profits are reported where economic activities are carried out and value created. Under the draft rules, MNCs will be a required to keep a Master File for every constituent entity of an international group with a consolidated revenue of over Rs500 crore as reflected in the consolidated financial statements (CFS) for the previous accounting year. The second condition is that the aggregate value of international transactions during the reporting accounting year should exceed Rs 50 crore or intangibles value exceeding Rs 10 crore. For CbCR to kick in, the total consolidated revenue of the international group has been pegged at Rs 5,500 crore or more in the CFS of the preceding accounting year.