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...
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...
The OECD announced on 15 June 2016, that on 23 May 2016, the OECD Council approved the amendments to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations ("Transfer Pricing Guidelines"), as set out in the 2015 BEPS Report...
On 9th May 2016 the International Consortium of Investigative Journalists (‘ICIJ’) undertook the next step in their release of the information obtained from the Panamanian law firm, Mossack Fonseca – the so-called Panama Papers – when they allowed public access...
On 17 September 2015, the Coca-Cola Company in the U.S. (“Coca-Cola U.S.”) received a statutory notice of deficiency (hereinafter “the notice”) from the Internal Revenue Service (“IRS”) for $3.3 billion U.S. Dollars (“USD”) excluding any interest for fiscal years 2007...
Agreement has been made between the EU Member States for the automatic exchange of information under the country-by-county (CbC) reporting framework. CbC reporting will require large multinational business to disclose certain financial information to tax authorities, analysing key financial information (including...
Following the release of the draft country-by-country (CbC) reporting regulations on 5 October 2015 for technical consultation, the final regulations The Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016 SI 2016/237 have now been laid before Parliament. The background to...
The OECD announced on 27 January 2016 that 31 countries have now signed Multilateral Competent Authority Agreement (MCAA) for the automatic exchange of Country-by-Country reports (CBCR). The use of a multilateral instrument enables certain changes to be introduced efficiently into...
"Is the taxation a poisoned chalice?" That is what many told to Commissionaire Pierre Moscovici when he found out that President Juncker had given him the taxation portfolio. In the last eighteen months, the European Commission’s and OECD’s strong commitment...
On 5 October, the OECD has issued the Final Reports on the BEPS 15 Action points and it is expected that the G20 Finance Ministers will discuss and endorse the Reports and the recommended changes at their meeting on 8...
The OECD reached a new milestone when the work on the development of the Multilateral Instrument to implement the tax treaty-related BEPS Action Plan began on 27 May 2015 in Paris. As per the OECD/G20 mandate, the ad hoc Group...
On 9-10 February 2015, the OECD presented the latest developments in the OECD/G20 project to combat BEPS by multinational enterprises during a G20 Finance Ministers and Central Bank Governors’ meeting in Istanbul, Turkey. In their Communiqué, the G20 Ministers and...
The Chancellor finally gave some more detail on his promise to tackle the techniques used by multinationals groups to shift profits offshore. This change will impact multinational groups like those which have been very publicly named and shamed in the...
Last week the UK government has confirmed that it will commit to implementing the country by country reporting template proposed by the OECD. The template is one of a number of measures being proposed by the OECD to tackle base...
On 2 April 2014 the OECD presented a second update on the BEPS (Base Erosion and Profit Shifting) project via a webcast, which is available for viewing on the OECD website (link). The key message was that the BEPS project...
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