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
| Jurisdiction | Threshold |
|---|---|
| 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.