UK country-by-country reporting
UK country-by-country reporting

The following Tax guidance note provides comprehensive and up to date legal information covering:

  • UK country-by-country reporting
  • What is country-by-country reporting?
  • Key definitions
  • What is the threshold for making CbC reports?
  • Which entity must file the report?
  • Notification obligations
  • What must be contained in a CbC report?
  • Practical considerations
  • Public CbC reporting

What is country-by-country reporting?

Country-by-country (CbC) reporting essentially requires large multinationals to provide an annual return that breaks down the key elements of its activities between the jurisdictions in which they operate.

The role of the OECD

Multinational enterprises (MNEs) are under increasing pressure to operate in a fair and transparent way, with particular regard to the payment of taxes and making a fair contribution to public finances. Meanwhile, governments across the globe are under pressure to reduce public deficits, generate higher tax revenues and tackle international tax avoidance. In response to these issues, the Organisation for Economic Cooperation and Development (OECD) has developed a range of proposals as part of the wider base erosion and profit shifting (BEPS) project. The final package of recommendations was published by the OECD on 5 October 2015.

CbC reporting is one of the areas covered by these proposals and the detailed recommendations are set out in the final report on Action 13: Transfer Pricing Documentation and Country-by-Country Reporting.

Certain MNEs are required to provide the relevant tax authorities with high-level details of the following:

  1. territories in which they have carried out economic activity

  2. the quantum of revenue and profits generated

  3. the amount of tax paid

The OECD has developed a model CbC reporting template, which is included in the final report on Action 13 (see

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