Country-by-Country reporting: Directions relating to notification requirements
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.
UPEs and UKEs are required to notify HMRC for each period covered by a CbC report.
HMRC seeks the following information in the notification:
- Which entity (including the unique taxpayer reference or equivalent) in the MNE group will file the CbC report and where;
- Whether exception A or B applies; and
- The names and unique taxpayer references of all of the MNE group’s entities that are tax resident in the UK, are UK permanent establishments of overseas group entities 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. Where there are multiple UPEs or UKEs needing to provide notification, HMRC will accept a notification submitted by one of the UPEs or UKEs as long as it is clear it is sent on behalf of all the relevant entities.
The deadline for notification is the later of end of the period to which the report relates or 1 September 2017 – see IEIM300029 for examples
HMRC would prefer the notification to be on a spreadsheet and sent to the dedicated mailbox which has been set up for this purpose – email@example.com. Where a notification is being sent by mail it should be sent to the address shown below and it should be marked “Country-by-Country Reporting Notification”.
HMRC CbCR Notifications
8th Floor Dorset House
Where the UKE and UPE are dealt with by HMRC Large Business, please send a copy of the notification to your CRM.