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Country-by-Country Reporting

Country-by-Country Reporting

With the first Country-by-Country Reporting (“CbCR”) deadline fast approaching, we have set some key points to be considered by multinational groups.


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With the first Country-by-Country Reporting (“CbCR”) deadline (for many) fast approaching, we have set out in this Tax Alert some key points to be considered by multinational groups.

CbCR is one of four “minimum standards” of the OECD’s Base Erosion and Profit Shifting (“BEPS”) project, the aim of which is to ensure businesses are taxed where economic activities generate profits and where value is created.

The Isle of Man Income Tax (Country-by-Country Reporting) Regulations 2017 (the “Regulations”) apply to accounting periods commencing on or after 1 January 2017 and require multinational enterprise (“MNE”) groups with consolidated group turnover of EUR 750m or more to file a CbCR report. The Isle of Man Income Tax Division (“ITD”) has published guidance (here) which is consistent with the guidance published by the OECD.

Similar rules have been enacted in other jurisdictions and, as such, there are various multi-jurisdictional interactions to consider, including:

  1. CbCR requirements in other jurisdictions in which the MNE group has entities.
  2. The exchange agreements in place between the Isle of Man and other jurisdictions (and vice versa).
  3. Other CbCR related reporting requirements (e.g. Local and Master filing).

The CbCR report contains specified data on an MNE’s international operations and must be submitted to the relevant tax authority annually by the group’s Reporting Entity (“RE”).

As well as the requirement to submit a CbCR report, there are also likely to be notification requirements for the RE and other group entities (known as Constituent Entities) in their respective jurisdictions.

Should you have any queries regarding the above, or if you need assistance with assessing your group’s reporting requirements (or indeed assistance with the submission of a CbCR report), please contact Robert Rotherham, Georgia Kenyon or your usual point of contact.

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