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 29 June 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     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
Brazil  1 January 2016 1 January 2016  N/A
Bulgaria   Not required 1 January 2016   1 January 2016    N/A
Canada        Not required 1 January 2016   1 January 2016
   N/A
Chile Not required    1 January 2016  No N/A    N/A
Colombia          1 January 2016****        1 January 2016**** 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
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 
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 2016  No  N/A
Ireland     1 January 2016   1 January 2016    N/A
Isle of Man     1 January 2017    1 January 2017    Yes
Israel     1 January 2016        N/A
Italy       1 January 2016    1 January 2016    N/A
Japan     1 April 2016   1 April 2016*    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 2017    N/A
Liechtenstein     1 January 2017   1 January 2017    Yes
Lithuania      1 January 2016   1 January 2017    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        
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
Poland     1 January 2016   1 January 2017    N/A
Portugal     1 January 2016   1 January 2016    N/A
Russian Federation     1 January 2017   1 January 2017    Yes
Singapore     1 January 2017    1 January 2017  No  Yes
Slovak Republic    

        1 January 2016

   1 January 2016    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 2016***       ***      1 January 2016***        ***  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

* Japan provides transition relief for the fiscal year commencing between 1 April 2016 and 31 March 2017 except the case of Systemic Failure.

** Switzerland: Draft legislation sent to Parliament on 23 November 2016 and approved by first chamber on 16 March 2017.

*** Turkey: In order to start the implementation, secondary regulations have to be in place, drafts are published but they are not officially issued.

**** Colombia: The obligation to file for such taxable year is conditioned to the issuance of secondary law.

 

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