The OECD has recently issued a consultation on country by country reporting (CBCR), and some analysis on the potential economic impact of its pillars 1 and 2 proposals for taxation of the digital economy (see here and here). Further details...
The OECD issued an announcement on 23 December 2019 concerning its updated country by country (CBCR) guidance - BEPS Action 13 to include responses to further questions concerning local filing requirements and obligations on exchange of information. It also published...
Many companies have 31 December year ends and in addition to corporation tax return filing deadlines, it may be helpful to consider other upcoming UK tax reporting deadlines. Some of these are noted below. There may well be other deadlines...
There are a number of notification and reporting obligations for companies and groups within the country by country reporting (CBCR) regime. There is an obligation for each UK entity (entity A) of a multinational enterprise (MNE) subject to CBCR to...
The OECD has updated its guidance on CBCR (see here). The updated guidance includes new information on: The treatment of dividendsUse of shortened or rounded amounts in table 1Deemed listing provisionsInformation on short/long accounting periodsInformation on sources of data for...
The European Parliament agreed on 24 October that its member states should require multinationals to publicly report those countries in which their tax is paid (rather than just the aggregate tax paid). The EU press release indicates this will allow...
On 27 March 2019 the European Parliament adopted the proposal for a Directive on public CBCR reporting and proposed some amendments. This will require the European Parliament and European Commission to agree the text to take forward. The progress of...
The OECD has included additional points in its September 2018 edition of guidance on country by country reporting (CBCR). The additional points cover the following areas: The treatment of dividends for the purposes of profit & loss before income tax,...
The OECD has released a report comparing different approaches taken by jurisdictions to implementing country by country reporting (CBCR). These differences arise because the OECD guidance provides the flexibility for jurisdictions to take different approaches. In particular, flexibility is provided...
The OECD has updated its guidance on country by country reporting with respect to two areas. These changes should not affect the majority of enterprises subject to CBCR. Definition of total consolidated group revenue Clarification is provided that where an...
The OECD has released updated guidance on implementing CBCR. The changes in this updated guidance compared to previous versions are noted below. Updated guidance Consolidated revenue The guidance on the definition of consolidated group revenue (for determining whether the 750m...
HMRC has updated its internal guidance on country by country reporting to include a preferred excel template for providing CBCR notifications. The HMRC guidance is also updated to say that HMRC’s online portal will validate a CBCR file before the...
The OECD has issued a September 2017 update to their guidance on country by country reporting (CBCR). In broad summary it contains further guidance on the following: Revenue – all revenue, gains income or other inflows included in the financial...
Many groups may have already made their notifications to HMRC in respect of the first year for which CBCR reporting is required. Notification is an annual obligation in the UK and for those already in the first year of reporting...
UK entities within the scope of country by country reporting (CBCR) for the first reporting periods to which the rules apply, will have either met or be preparing to meet the notification deadline. For those UK entities which have non-UK...
Background In its last month in office, the Maltese presidency of the EU has issued proposals for an amended directive on public disclosure of income tax information by certain undertakings and branches. This is part of the EU’s desire to...
The OECD has announced that more than 700 automatic exchange relationships have now been established among jurisdictions committed to exchanging CbC Reports as of 2018, including those between EU Member States under EU Council Directive 2016/881/EU. A full list of...
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