Country-Specific Information on Country-by-Country Reporting Implementation
The Inclusive Framework on BEPS has released information on the domestic legal frameworks for Country-by-Country (CbC) reporting around the world. This provides a high level snapshot for tax administrations and MNE Groups as to the first reporting periods, availability of surrogate filing including in the parent jurisdiction, and local filing. The table below contains the information received from members so far and will be updated as Inclusive Framework members continue to finalise their CbC reporting frameworks.
Last modified 13 December 2017
1 Colombia: The obligation to file for such taxable year is conditioned to the issuance of secondary law.
2a Israel: It is likely that CbC Reporting requirements will apply for fiscal years commencing on or after 1 January 2017.
2b Israel: Israel allows voluntary parent surrogate filing for fiscal years commencing on or after 1 January 2016 that will be exchanged after legislation will be in place.
3 Japan provides transition relief for the fiscal year commencing between 1 April 2016 and 31 March 2017 except the case of Systemic Failure.
4 Turkey: In order to start the implementation, secondary regulations have to be in place, drafts are published but they are not officially issued.
5 Cayman Islands: In progress
6 Russian Federation: Secondary legislation is not required for the voluntary parent surrogate filing mechanism.
7 Russian Federation: The Russian Federation allows voluntary parent surrogate filing for the fiscal years starting on or after 1 January 2016 and intends to exchange the CbC reports it receives as such with other jurisdictions with which it has bilateral relationships under the CbC MCAA.
8 Indonesia: When local filing is applicable in Indonesia, for the 2016 taxable year the taxpayer should notify the DGT no later than the end of March 2018 and the CbC report must be filed using DGT Online system no later than the end of April 2018. The receipt of such filings shall be attached as an attachment of the Annual Corporate Income Tax return for the 2017 taxable year, ie. in April 2018.