Case study 1
Designation settled between three Indian entities before the report was prepared
A group brought three Indian constituent entities inside its country-by-country reporting and had never allocated the obligation between them. Each finance team assumed one of the others held it. We set out what the designation does, established which entity could realistically obtain the group figures and sign on time, obtained the group's decision in writing, and filed the designation for the reporting period. The engagement produced a recorded designated filer, a written instruction from head office behind it, and one point of responsibility for the report that follows.
Read how this one runs
Case study 2
Obligation reallocated after the designated Indian entity was sold
A group sold the Indian company it had previously designated to discharge the country-by-country obligation, and the designation still pointed at an entity no longer in the group. We identified the reporting period in which the change took effect, agreed the replacement entity with head office, and made the filing that moved the obligation. The engagement produced the new designation, a note tying it to the disposal date, and a corrected compliance calendar, so that the outgoing entity's team stopped preparing for a filing that was no longer theirs.
Read how this one runs
Case study 3
Duplicate reporting unwound where two Indian entities had each filed
Two Indian entities in the same group each prepared and submitted the group report, neither aware of the other, because no designation had ever been made. We established which entity the group intended to carry the obligation, filed the designation, and set out the position on the duplicated submissions for the record. The engagement produced a designated filer, a written chronology of what had been filed and by whom, and a prepared response held ready in case either submission is queried.
Read how this one runs
Case study 4
Dormant holding company replaced as the designated Indian filer
A group had named the entity at the top of its Indian structure as designated filer. That company was dormant, had no finance staff, and depended on a sister company for everything. The obligation and the capacity to discharge it sat in different places. We reviewed which Indian entity actually held the data and the signing officers, obtained the group's agreement to move the designation, and filed it. The engagement produced a designation that matches where the work is done, and a short handover note between the two Indian teams.
Read how this one runs
Case study 5
Designation made for a joint venture whose parent group changed
An Indian joint venture company came inside a different group's country-by-country reporting after a shareholding change, alongside that group's existing Indian entities. Nobody had asked who would file. We worked out which companies were now constituent entities of the same group, whether more than one of them sat in India, and therefore whether a designation was needed at all. It was. The engagement produced the filed designation, a note of the shareholding change that triggered it, and a list of the facts that would require it to be revisited.
Read how this one runs
Case study 6
Designation and local filing questions taken in the right order
An Indian entity asked us to prepare a group report it might not have been required to file. We took the questions in sequence instead. First, whether the group's parent jurisdiction exchanged the report with India, which decides whether anything is filed locally at all. Then, given several Indian entities, which of them would carry it. The engagement produced a written position on both points, the designation filing that followed from the second, and a documented decision not to prepare a report the group did not have to file.
Read how this one runs
Case study 7
Interest and Penalties Put to a Relief Application
Relief is discretionary and is decided on the circumstances that caused the delay, evidenced year by year. The application is built from the same chronology the filings rest on, so the two cannot contradict each other.
Read how this one runs
Case study 8
Information Returns Missed Behind a Correct Return
The heaviest exposure on a cross-border file is often a disclosure form rather than the tax. Where the return itself was right, the procedures for late information returns turn on a reasonable-cause narrative with dates and documents behind it.
Read how this one runs
