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HMRC internal manual

International Exchange of Information Manual

Country-by-Country reporting: Appropriate use of Country by Country reporting data

CbC reporting data received by HMRC under an international agreement from another tax authority is subject to conditions of use set by that agreement.  The data will be clearly marked where that is the case and resulting conditions must be met.    


The agreement under which HMRC has obtained the report requires HMRC to use the data for the following purposes only:


• high level transfer pricing risk assessment

• assessment of other base erosion and profit shifting related risks

• economic and statistical analysis, where appropriate.


In addition HMRC has agreed not to use CbC reporting data as a substitute for a detailed transfer pricing analysis of individual transactions and prices based on a full functional analysis and a full comparability analysis.

The information in the CbC Report on its own does not constitute conclusive evidence that transfer prices are or are not appropriate and further details, information and documents will always need to be considered in order to substantiate any risk indicated by the report.