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HMRC internal manual

International Exchange of Information Manual

Country-by-Country reporting: Voluntary filing of CbC reports

The UK rules use many terms and definitions that are taken from the OECD guidance and that guidance should be checked when completing a CbC report.

Any entity of an MNE group may voluntarily file a report on the group’s behalf if there is a member of that group resident in the UK and:

  • the UPE of the MNE group is resident in a country that does not require it to file a CbC report or
  • the UPE of the MNE group is resident in a country that has entered into an international agreement which allows for exchange of information (like the Multilateral Convention for Mutual Administrative Assistance in Tax Matters or similar), but has not entered into specific arrangements to exchange CbC reports, or
  • HMRC has notified the entity that exchange arrangements with the country in which the UPE is resident are not operating effectively Where an entity wishes to file a CbC report voluntarily the ultimate parent entity must notify HMRC in writing that the entity has the authority to do so on or before the filing deadline.