In the Finance Act, 2016, the Indian government has introduced a regime regarding the country-by-country report and the master file under Indian tax law. A partial version of the proposed regime is introduced in the Finance Act, 2016. More specific rules and the format for the master file and country-by-country report will be prescribed in the future. In this article, the author reviews the proposed regime regarding the country-by-country report and the master file, and its anticipated impact on Indian taxpayers.