This measure introduces a new statutory requirement for UK headed Multinational enterprises (MNEs), or UK sub groups of MNEs, to make an annual country-by-country report to HM Revenue and Customs (HMRC).
This measure will require UK headed MNEs and enable non-UK headed MNEs to provide HMRC with information about global activities, profits and taxes.
More information can be found at The Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016 No. 237.
This legislation updates the Country-by-Country (CbC) reporting regulations The Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) (Amendment) Regulations 2017 to take account of international developments. In particular the legislation:
- brings partnerships into scope
- amends the UK ‘local filing’ requirements
- introduces a notification requirement
HMRC has published guidance on the notification requirement in the International Exchange of Information Manual and will publish full guidance in due course. A tax information and impact note has also been published please read Amendments to Country By Country reporting 2017.