COUNTRY-BY-COUNTRY REPORT Report by a parent entity or an alternate reporting entity or any other constituent entity, resident in India, for the purposes of section 511(2) or section 511(4)

Place: Signature:

Date: Name:

Designation:

Notes:

1. Name shall include full name of the reporting entity.

2. The address shall include flat/door/building, road/street/block/sector, area/locality, post office, town/city/district, state, country and pin code.

3. Address type of constituent entity shall be selected from the following: __

(a) Residential

(b) Residential or business

(c) Business

(d) Registered

(e) Unspecified

4. Main business activity shall be selected from the following: __

(a) Research and Development

(b) Holding/Managing intellectual property

(c) Purchasing or Procurement

(d) Manufacturing or Production

(e) Sales, Marketing or Distribution

(f) Administrative, Management or Support Services

(g) Provisions of services to unrelated parties.

(h) Internal group finance

(i) Regulated financial services

(j) Insurance

(k) Holding shares of other equity instruments.

(l) Dormant

(m) Other

5. In the column titled “Tax Jurisdiction”, the Reporting multi-national enterprise (MNE) should list all of the tax jurisdictions in which Constituent Entities of the MNE group are resident for tax purposes. A tax jurisdiction is defined as a State as well as a non-State jurisdiction which has fiscal autonomy. A separate line should be included for all Constituent Entities in the MNE group deemed by the Report- ing MNE not to be resident in any tax jurisdiction for tax purposes. Where a Constituent Entity is res- ident in more than one tax jurisdiction, the applicable tax treaty tie breaker should be applied to de- termine the tax jurisdiction of residence. Where no applicable tax treaty exists, the Constituent Entity should be reported in the tax jurisdiction of the Constituent Entity‘s place of effective management.

6. In the three columns of the template under the heading “Revenues”, the Reporting MNE should report the following information: (i) the sum of revenues of all the Constituent Entities of the MNE group in the relevant tax jurisdiction generated from transactions with associated enterprises; (ii) the sum of revenues of all the Constituent Entities of the MNE group in the relevant tax jurisdiction generated from transactions with independent parties; and (iii) the total of (i) and (ii). Revenues should include revenues from sales of inventory and properties, services, royalties, interest, premiums and any other amounts. Revenues should exclude payments received from other Constituent Entities that are treated as dividends in the payer‘s tax jurisdiction.

7. Under the column titled “Profit (Loss) before Income Tax”, the Reporting MNE should report the sum of the profit (loss) before income tax for all Constituent Entities resident for tax purposes in the rele- vant tax jurisdiction. The profit (loss) before income tax should include all extraordinary income and expense items.

8. Under the column titled “Income Tax Paid (on Cash Basis)”, the Reporting MNE should report the to- tal amount of income tax actually paid during the relevant fiscal year by all Constituent Entities resi- dent for tax purposes in the relevant tax jurisdiction. Taxes paid should include cash taxes paid by the Constituent Entity to the residence tax jurisdiction and to all other tax jurisdictions. Taxes paid should include withholding taxes paid by other entities (associated enterprises and independent enterprises) with respect to payments to the Constituent Entity. Thus, if company A resident in tax jurisdiction A earns interest in tax jurisdiction B, the tax withheld in tax jurisdiction B should be reported by com-

panyA.

9. Under the column titled “Income Tax Accrued – Reportable Accounting Year”, the Reporting MNE should report the sum of the accrued tax expense recorded on taxable profits or losses of the year of reporting of all Constituent Entities resident for tax purposes in the relevant tax jurisdiction. The tax expense should reflect only operations in the reportable accounting year and should not include de- ferred taxes or provisions for uncertain tax liabilities.

10. Under the column titled “Stated Capital”, the Reporting MNE should report the sum of the stated cap- ital of all Constituent Entities resident for tax purposes in the relevant tax jurisdiction. With regard to permanent establishments, the stated capital should be reported by the legal entity of which it is a permanent establishment unless there is a defined capital requirement in the permanent establishment tax jurisdiction for regulatory purposes.

11. Under the column titled “Accumulated Earnings”, the Reporting MNE should report the sum of the total accumulated earnings of all Constituent Entities resident for tax purposes in the relevant tax ju- risdiction as of the end of the year. With regard to permanent establishments, accumulated earnings should be reported by the legal entity of which it is a permanent establishment.

12. Under the column titled “Number of Employees”, the Reporting MNE should report the total number of employees on a full-time equivalent (FTE) basis of all Constituent Entities resident for tax purpos- es in the relevant tax jurisdiction. The number of employees may be reported as of the year-end, on the basis of average employment levels for the year, or on any other basis consistently applied across tax jurisdictions and from year to year. For this purpose, independent contractors participating in the ordinary operating activities of the Constituent Entity may be reported as employees. Reasonable rounding or approximation of the number of employees is permissible, providing that such rounding or approximation does not materially distort the relative distribution of employees across the various tax jurisdictions. Consistent approaches should be applied from year to year and across entities.

13. Under the column titled “Tangible Assets other than Cash and Cash Equivalents”, the Reporting MNE should report the sum of the net book values of tangible assets of all Constituent Entities resident for tax purposes in the relevant tax jurisdiction. With regard to permanent establishments, assets should be reported by reference to the tax jurisdiction in which the permanent establishment is situated. Tan- gible assets for this purpose do not include cash or cash equivalents, intangibles, or financial assets.

14. Under the column titled “Constituent Entities Resident in the Tax Jurisdiction”, the Reporting MNE should list, on a tax jurisdiction-by-tax jurisdiction basis and by legal entity name, all the Constituent Entities of the MNE group which are resident for tax purposes in the relevant tax jurisdiction. As stat- ed above with regard to permanent establishments, however, the permanent establishment should be listed by reference to the tax jurisdiction in which it is situated. The legal entity of which it is a per- manent establishment should be noted (e.g. XYZ Corp – Tax Jurisdiction A PE).

15. Under the column titled “Tax Jurisdiction of Organization or Incorporation if different from Tax Ju- risdiction of Residence”, the Reporting MNE should report the name of the tax jurisdiction under whose laws the Constituent Entity of the MNE is organised or incorporated if it is different from the tax jurisdiction of residence.

16. Under the column titled “Main Business Activity(-ies)”, the Reporting MNE should determine the na- ture of the main business activity(ies) carried out by the Constituent Entity in the relevant tax jurisdic- tion, by ticking one or more of the appropriate boxes. In this column, if the Reporting MNE chooses the option ‘Other‘, then it shall be required to specify the nature of the activity of the Constituent En- tity in the “Part C: Additional Information” section.