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HMRC internal manual

International Exchange of Information Manual

Country-by-Country reporting: UPEs - Direction relating to contents of the CbC report

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.

The report must be made in the XML format agreed at the OECD and which is acceptable for the EU. The report will show for each country (tax jurisdiction) in which the multinational carries on business:

  • the amount of revenue, profit before income tax and income tax paid and accrued; and
  • their total employment, capital, retained earnings and tangible assets.

UK UPEs will also have to identify each entity within their group doing business in a particular country and say what sort of business activity the entity is engaged in.

The OCED has issued guidance on the XML schema here

HMRC’s schema guidance is here