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.

Jurisdictions

Last modified 13 December 2017

A B C D F G H I J K L M N P R S T U 

  

Jurisdiction

Primary law in place

Secondary law in place

First fiscal year covered for filing by Ultimate Parent Entity

Local Filing required?

First fiscal period for which local filing applies

Surrogate Filing available?

Parent Surrogate Filing (i.e voluntary filing in parent jurisdiction)?

Argentina  Not required   1 January 2017   1 January 2017    No
‌Australia     1 January 2016   1 January 2016    N/A
Austria   Not required  1 January 2016   1 January 2017    N/A
Belgium     1 January 2016  
1 January 2016    N/A
Bermuda 1 January 2016 No N/A N/A
Brazil  1 January 2016 1 January 2016  N/A
Bulgaria   Not required 1 January 2016   1 January 2017    N/A
Canada Not required 1 January 2016   1 January 2016
   N/A
Cayman Islands 5 1 January 2016 No N/A To be advised  N/A
Chile Not required    1 January 2016  No N/A    N/A
Colombia  

 1 January 20161

 1 January 20161 No  N/A
Croatia     1 January 2016     1 January 2017    N/A
Czech Republic     1 January 2016   1 January 2017    N/A
Denmark     1 January 2016   1 January 2017    N/A
Estonia   1 January 2016 1 January 2017  N/A
Finland 1 January 2016 1 January 2016 N/A
France     1 January 2016   1 January 2016    N/A
Gabon     1 January 2017 To be advised N/A

To be advised

To be advised

Germany
Not required 1 January 2016   1 January 2017    N/A
Greece     1 January 2016 1 January 2016  N/A
Guernsey     1 January 2016   1 January 2016  
 N/A
Hong Kong, China     1 January 2018   1 January 2018    Yes 
Hungary Not required 1 January 2016 1 January 2017  N/A
Iceland 1 January 2017 1 January 2017    N/A
India     1 April 2016   1 April 2016    N/A
Indonesia Not required   1 January 2016   1 January 20167  No  N/A
Ireland     1 January 2016   1 January 2016    N/A
Isle of Man     1 January 2017    1 January 2017    Yes
Israel  2a  
2a  Yes   1 January 2017 To be advised   Yes2b
Italy       1 January 2016    1 January 2016    N/A
Japan     1 April 2016   1 April 20163    Yes
Jersey     1 January 2016   1 January 2016    N/A
Korea      1 January 2016   1 January 2016  No  N/A
Latvia     1 January 2016   1 January 2016    N/A
Liechtenstein     1 January 2017   1 January 2017    Yes
Lithuania      1 January 2016   1 January 2016    N/A
Luxembourg     1 January 2016    1 January 2016    N/A
Malaysia     1 January 2017  No N/A    No
Malta       1 January 2016   1 January 2017    N/A
Mauritius   1 July 2018  No N/A    No 
Mexico     1 January 2016   1 January 2016    N/A
Norway 1 January 2016 1 January 2017 N/A
Netherlands     1 January 2016   1 January 2016    N/A
New Zealand   Not  required 1 January 2016  No N/A  No  N/A
Nigeria         1 January 2017    Yes
People's Republic of China     1 January 2016   1 January 2016    N/A
Peru   1 January 2017 1 January 2017  N/A
Poland     1 January 2016   1 January 2017    N/A
Portugal     1 January 2016   1 January 2017    N/A
Romania   1 January 2016 1 January 2017  N/A
Russian Federation    6 1 January 2017   1 January 2017    Yes7
Singapore     1 January 2017    1 January 2017  No  Yes
Slovak Republic    Not required

        1 January 2016

   1 January 2017    N/A

Slovenia

    1 January 2016   1 January 2017  N/A
South Africa       1 January 2016   1 January 2016  No  N/A
Spain     1 January 2016   1 January 2016    N/A
Sweden      1 January 2016   1 January 2016    N/A
Switzerland  

1 January 2018   1 January 2018    Yes
Turkey        1 January 20164      4    1 January 20164 
   4
 N/A
United Kingdom      1 January 2016   1 January 2016    N/A
United States     30 June 2016  No N/A  No  Yes
Uruguay      1 January 2017   1 January 2017    No

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.

Cayman Islands: In progress

6 Russian Federation: Secondary legislation is not required for the voluntary parent surrogate filing mechanism.

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. 

 

 

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