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HMRC internal manual

International Exchange of Information Manual

Country-by-Country reporting: Examples of filing and notification obligations

(i) A UK UPE

UK UPE has revenue in excess of €750 million shown in its consolidated financial statements for year ended 31/12/2015. 

CbC reporting filing obligation: It will have to submit a CbC report for the period 01/01/16 – 31/12/16.    This report must be submitted by 31/12/17.

Assuming the threshold requirement was met for year ended 31/12/16, the UK UPE will have to submit a CbC report covering 01/01/17 to 31/12/17.  This report must be filed by 31/12/18.

Notification obligation: For the CbC report for the year ended 31/12/16 a notification as set out in para 11 must be sent to HMRC by 1 September 2017.

For the CbC report for the year ended 31/12/17 the notification must be sent to HMRC by 31/12/17.

Note: If another UPE of the MNE group has provided a notification that contains the information required then the UPE does not have to notify as long as it tells HMRC, by the deadline for notification, which UPE notified and the date when that notification was provided. HMRC will accept a notification submitted by one of the UPEs as long as it is clear it is sent on behalf of the others.

(ii) UKE that does not have an obligation to file a CbC report

UKE is the top UK entity of an MNE group which has revenue in excess of €750 million shown in its consolidated financial statements for year ended 31/12/2015. The UPE for the MNE group is resident in a jurisdiction that will require a CbC report and will exchange with the UK.

CbC reporting obligation: none

Notification obligation: For the CbC report for the year ended 31/12/16 a notification as set out in para 11 must be sent to HMRC by 1 September 2017.

For the CbC report for the year ended 31/12/17 the notification must be sent to HMRC by 31/12/17.

Note: If another UKE of the MNE group has provided a notification that contains the information required then the UKE does not have to notify as long as it tells HMRC, by the deadline for notification, which UKE notified and the date when that notification was provided. HMRC will accept a notification submitted by one of the UKEs as long as it is clear it is sent on behalf of the others.

 

(iii) UKE that has an obligation to, and will, file a CbC report

UKE is the top UK entity of an MNE group which has revenue in excess of €750 million shown in its consolidated financial statements for year ended 31/12/2015. The UPE for the MNE group is resident in a jurisdiction that does not require a CbC report.

 

CbC reporting obligation: It is required to file a CbC report for the period 1/1/16 to 31/12/16.  The report must be filed by 31/12/17.

Before 31/12/17, UKE must ask its parent for the information to complete a CbC report.  If the information is not provided, the UKE must inform HMRC in writing that the parent has not provided the information and it must file a UK CbC report by 31/12/17.

Assuming the threshold requirement was met for year ended 31/12/16, the UKE will have to submit a CbC report covering 01/01/17 to 31/12/17.  This report must be filed by 31/12/18. Before 31/12/18, UKE must ask its parent for the information to complete a CbC report.  If the information is not provided, the UKE must inform HMRC in writing that the parent has not provided the information and it must file a UK CbC report by 31/12/18.

Notification obligation: For the CbC report for the year ended 31/12/16 a notification as set out in para 11 must be sent to HMRC by 1 September 2017.

For the CbC report for the year ended 31/12/17 the notification must be sent to HMRC by 31/12/17.

Note: If another UKE of the MNE group has provided a notification that contains the information required then the UKE does not have to notify as long as it tells HMRC, by the deadline for notification, which UKE notified and the date when that notification was provided. HMRC will accept a notification submitted by one of the UKEs as long as it is clear it is sent on behalf of the others.

 

(iv) UKE that has an obligation to file a CbC report but will apply one of the exceptions

UKE is the top UK entity of an MNE group which has revenue in excess of €750 million shown in its consolidated financial statements for the year ended 31/12/2015. The UPE for the MNE group is resident in a jurisdiction that does not require a CbC report.

However another entity of the MNE group files an equivalent CbC report which includes the information the UKE would have been required to send to HMRC.

CbC reporting obligation: It is required to file a CbC report for the period 1/1/16 to 31/12/16.  The report must be filed by 31/12/17. However in this case another group entity has filed an equivalent CbC report containing the relevant information with a jurisdiction that will exchange with HMRC. The UKE wants to apply Exception B.

Before the filing deadline (31/12/17) the UKE must tell HMRC which entity has filed the CbC report, the date the report was filed and the jurisdiction in which it was filed.

Assuming the facts were similar for the CbC report for the year ended 31/12/17 the UKE would need to provide HMRC with the same details by 31/12/18.

Notification obligation: For the CbC report for the year ended 31/12/16 a notification as set out in para 11 must be sent to HMRC by 1 September 2017.

For the CbC report for the year ended 31/12/17 the notification must be sent to HMRC by 31/12/17.

Note: If another UKE of the MNE group has provided a notification that contains the information required then the UKE does not have to notify as long as it tells HMRC, by the deadline for notification, which UKE notified and the date when that notification was provided. HMRC will accept a notification submitted by one of the UKEs as long as it is clear it is sent on behalf of the others.