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HMRC internal manual

International Exchange of Information Manual

Country-by-Country reporting: Introduction

Country-by-country reporting was designed as part of the OECD BEPS project to provide tax authorities with a clear overall picture of the global position on profit and tax of the multinational (MNE) groups operating in their jurisdiction. This will enable tax authorities to make a more informed assessment of where risks lie.

The OECD’s final report on Action 13 – Country by Country reporting was published in October 2015.  The report details a three tiered approach to standardise transfer pricing documentation.  The three tiers are a master file, local file and the country-by-country report. 

The UK’s regulations implementing the OECD model for Country-by-Country (CbC) reporting came into force on 20 March 2016 and were amended in March 2017 to take account of international developments.