Rule 27 F

27F. The provisions of rule 27E shall not apply, if a surrogate parent entity of the MNE group has furnished a country-by-country report with respect to any reporting fiscal year with the tax authority of country or territory of which the surrogate parent entity is a resident on or before the date specified under rule 27Gand satisfies the following conditions, namely:-

(a) the surrogate parent entity is required to file the country-by-country reports in the country or territory in which such entity is resident;

(b) the country or territory in which the surrogate parent entity is resident has a competent authority agreement with Pakistan;

(c) the country or territory in which the surrogate parent entity is resident has not intimated the Board of a systemic failure;

(d) the country or territory in which the surrogate parent entity is resident has been intimated in writing by the said entity that it is the surrogate parent entity designated by the MNE group; and

(e) the Board has been intimated in accordance with rule 27D.