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HMRC internal manual

International Exchange of Information Manual

CBC: Notification requirements

Country-by-Country reporting: Notification requirements


Ultimate Parent Entities (UPEs) and the top UK entities (UKEs) of MNE groups in scope are required to notify HMRC for each period covered by a CbC report:

  • Which entity (including the unique taxpayer reference or equivalent) in the MNE group will file the CbC report and where; and
  • The names and unique taxpayer references for all of the MNE group’s entities that are resident in the UK, are UK permanent establishments or are UK partnerships.

To avoid duplication UPEs and UKEs will not have to notify if another UPE or UKE of the MNE group has provided a notification which contains all the information that would have been required and it has provided HMRC with the identity of the UPE or UKE that has notified and the date that took place by the deadline.

The deadline for notification is the later of the end of the period to which the report relates or the 1 September 2017.

There is no specific form for the notification HMRC would prefer the notification to be on a spreadsheet and a dedicated mailbox has been set up for this purpose:

Where the UKE and UPE are dealt with by HMRC Large Business, please send a copy of the notification to your CRM.