Rule 10E: India’s CbCR Rule (Form 3CEB / 3CEBA Reporting)

Definition

Rule 10E is the Indian rule that gives effect to the country-by-country reporting (CbCR) obligation under section 92F of the Income-tax Act — the rule of the Income-tax Rules, 1962, that prescribes who files the CbCR in India and in what form. The section (92F) 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); Rule 10E and its companion rules set the mechanics: Rule 10E (the filing — by the ultimate parent entity (UPE) resident in India, or the surrogate parent entity (SPE), or the head office of the group in India — where the CbCR is prepared in India), Rule 10EA (the Form 3CEB — the full per-jurisdiction CbCR, filed with the return of income for the year), Rule 10EB (the Form 3CEBA — the Indian constituent entity’s CbCR statement, where the CbCR is prepared outside India, likewise filed with the constituent’s return), and Rule 10EC (the information exchange between the Indian authority and the parent’s jurisdiction — the channel by which the CbCR prepared abroad reaches India). The CbCR’s data (the per-jurisdiction revenues — external and related-party, the profit before tax, the tax paid and currently due, the employees, the tangible assets) is the BEPS Action 13 third pillar, and it is the document the competent authorities exchange automatically — the cbcr guide carries the full threshold, filing and data-quality treatment.

Rule 10E, in one filing chain:
  1. The scope (the MNE group — consolidated revenue ≥ ₹1,000 cr — section 92F)
  2. The preparer (the UPE in India / the SPE / the head office in India — where India prepares)
  3. The form (Form 3CEB — the full CbCR, with the return of income)
  4. The constituent's form (Form 3CEBA — where the CbCR is prepared outside India)
  5. The exchange (Rule 10EC — the parent's jurisdiction's CbCR to the Indian authority)

The element	The content
The duty (the section)	Section 92F — the MNE group with consolidated revenue ≥ ₹1,000 cr reports per jurisdiction (the CbCR data — the revenues split, the profit, the tax, the employees, the tangible assets)
Rule 10E (the filing)	The CbCR prepared in India is filed by the UPE resident in India / the SPE / the head office in India — the preparer role, the rule’s core
Rule 10EA (Form 3CEB)	The full per-jurisdiction CbCR — filed with the return of income for the year (the Form 3CEB term)
Rule 10EB (Form 3CEBA)	The Indian constituent entity’s statement, where the CbCR is prepared outside India — filed with the constituent’s return (the Form 3CEBA term)
Rule 10EC (the exchange)	The information exchange with the parent’s jurisdiction — the channel for the CbCR prepared abroad

The working read (the CbCR guide): Rule 10E is the Indian layer of a three-layer CbCR obligation — the OECD standard (the [BEPS Action 13] (/docs/glossary/beps-action-13) design, the €750 mn scope), the domestic implementation (India’s 92F + the 10E-family rules, the ₹1,000 cr scope), and the exchange (the AEoI channel the 10EC carries). The practice questions the rule answers: who files in India (the preparer hierarchy — the UPE in India, else the SPE, else the head office in India; and the constituent’s 3CEBA where the preparation is abroad), when (with the return of income — the [compliance calendar] (/docs/documentation/india-compliance-calendar) carries the date), and what reaches the Indian authority (the full CbCR by preparation or by exchange). The data-quality stakes are the [CbCR guide’s] (/docs/documentation/cbcr-guide) standing warning: the CbCR is the authorities’ risk-assessment input — the per-jurisdiction rows that do not reconcile with the Master File and the Local File (the same group data, three documents) are the rows that open the examination, and the shared underlying data (the segment and country breakdowns) is the reconciliation discipline the rule’s filings presuppose. Where the group’s CbCR data also feeds Pillar Two (the same €750 mn scope family, the ETR computation), the data-quality discipline is doubled — the [CbCR and Pillar Two] (/docs/pillar-two/cbcr-and-pillar-two) guide carries the interaction.

Example

An MNE group: the UPE is in Singapore (consolidated revenue ₹3,200 cr — in scope); the Indian operations are two constituent entities (the manufacturing subsidiary, the services subsidiary). The Rule 10E chain:

The question	The answer
Who prepares the CbCR?	The Singapore UPE (its jurisdiction’s regime — the group CbCR, all jurisdictions)
Who files in India?	The Indian constituent entities — Form 3CEBA each (the Rule 10EB form), with their returns of income (the CbCR is prepared outside India — the 3CEB preparer role does not arise in India)
How does the full CbCR reach India?	The exchange (Rule 10EC) — the Indian authority obtains the Singapore-prepared CbCR from the Singapore authority (the AEoI channel)
The data check	The two Indian rows in the group CbCR reconcile with the constituents’ 3CEBA data and with the Local File / Master File country breakdowns (the reconciliation discipline)

The Indian entities’ obligation is the 3CEBA (the constituent’s statement) — not the full 3CEB (that is the Singapore UPE’s, in its jurisdiction). The 3CEBA’s data is the Indian rows; the exchange carries the full report; and the reconciliation across the three (the CbCR rows, the 3CEBA, the Local/Master File breakdowns) is the data-quality check the examination starts from.

See also

• CbCR (Country-by-Country Reporting)
• Form 3CEB
• CbCR Guide — Thresholds, Filing, Data Quality
• Master File (Rule 10DA)

FAQ

What is the difference between Rule 10E and Rule 10EA/10EB/10EC? Rule 10E is the filing rule (who files the CbCR in India — the UPE/SPE/head office in India where it is prepared here); 10EA prescribes the Form 3CEB (the full CbCR’s form and particulars); 10EB prescribes the Form 3CEBA (the constituent entity’s statement, where the preparation is abroad); 10EC prescribes the information exchange (the channel for the CbCR prepared outside India). The family is one obligation (the 92F duty) expressed in filing, form-3CEB, form-3CEBA, and exchange rules — the cbcr guide maps the four.

When is the 3CEB filed in India — and when is it the 3CEBA instead? The 3CEB (the full CbCR) is filed in India where the CbCR is prepared in India — the UPE is resident in India, or the SPE role or the head-office-in-India role applies (the Rule 10E preparer). Where the CbCR is prepared outside India (the UPE abroad), the Indian constituent entities file the 3CEBA (their statement, the Indian rows) and the full CbCR reaches India by the exchange (Rule 10EC) — the two channels, the one data. The compliance calendar carries both filings’ dates (with the return of income).

Does the CbCR threshold interact with the Master File threshold? The Indian CbCR scope is the ₹1,000 cr consolidated-revenue test (section 92F); the Master File scope (Rule 10DA) is the family’s related test — a group that crosses the CbCR threshold almost always crosses the Master File’s too, and the two documents share the underlying country/segment data. The interaction is the [data-quality] (/docs/documentation/cbcr-guide) point: the three documents (CbCR, Master File, Local File) on the same group data must reconcile — the row that differs across the three is the scrutiny trigger, and the Rule 10E filings are where the CbCR side of the reconciliation sits.