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Direct Tax Code / Income Tax

India's CbCR Threshold — The ₹6,400 Crore Consolidated Revenue Test Explained

A comprehensive guide to India's ₹6,400 crore CbCR threshold, explaining the consolidated revenue test and compliance implications.

25 Jul 20262 min read

The ₹6,400 crore consolidated revenue threshold is the gateway to CbCR compliance in India. Understanding this threshold is essential for multinational enterprises operating in India.

The Threshold

The Rule

The CbCR filing obligation applies where the total consolidated group revenue of the international group equals or exceeds ₹6,400 crore . This threshold is aligned with the OECD's €750 million recommendation .

Applicability

The threshold applies to:

  • Parent entities resident in India
  • Alternate reporting entities resident in India
  • Constituent entities resident in India (in specified circumstances)

Foreign Currency Conversion

Where the total consolidated group revenue is in foreign currency, the rate of exchange for conversion shall be the telegraphic transfer buying rate of such currency on the last day of the accounting year preceding the accounting year .

Comparison with Other Jurisdictions

JurisdictionThreshold
OECD Recommendation€750 million
India₹6,400 crore (approx. €750 million)
United States$850 million
United Kingdom€750 million

Implications

For Groups Below Threshold

If the consolidated group revenue is below ₹6,400 crore, there is no CbCR filing obligation in India. However, other transfer pricing documentation requirements (such as master file) may still apply.

For Groups Above Threshold

If the consolidated group revenue equals or exceeds ₹6,400 crore:

  • Parent entity or alternate reporting entity must file CbCR
  • Constituent entities must provide notifications
  • Nine-year retention of documentation is required

Calculating Consolidated Group Revenue

Scope

Consolidated group revenue includes revenue from all entities included in the consolidated financial statement of the group.

Timing

The threshold is tested based on the consolidated financial statement for the accounting year preceding the reporting accounting year.

Currency

Revenue denominated in foreign currency must be converted using the telegraphic transfer buying rate on the last day of the accounting year preceding the accounting year.

Expert Legal Guidance

Understanding the CbCR threshold is essential for multinational enterprises. Anuj Desai & Associates provides expert advisory services on international tax compliance, helping taxpayers assess CbCR obligations.


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