Beta This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

International Exchange of Information Manual

CBC: Background

Country-by-Country reporting: Background


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.

Further guidance will follow.

The following page gives interim guidance for enterprises with an obligation to notify HMRC under the Country-by-Country reporting regulations.