This article examines the implementation of country-by-country (CbC) reporting in India and to whom it is applicable. It also discusses the exchange mechanism through which CbC reports will be given and received between various jurisdictions. The impact of signing the bilateral intergovernmental agreement (BIGA) between India and the United States for the exchange of CbC reports is analysed next. The article ends by discussing the legal aspect of signing the BIGA and the procedure envisaged in the proposed Bilateral Competent Authority Agreement and the way forward.