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 23 February 2018
1 People's Republic of China: As the Convention on Mutual Administrative Assistance in Tax Matters is in effect from 1 January 2017, China will not apply local filing requirements for the 2016 fiscal year, as a transitional relief.
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: 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: The secondary regulation has not been published yet. In order to implement CbC Reporting the secondary regulation has to be in place.
5 Curaçao: Curaçao indicates that voluntary filing will be available for fiscal years 2016 and 2017 as per the primary legislation which is currently going through the legislative process.
6a Russian Federation: Secondary legislation is not required for the voluntary parent surrogate filing mechanism.
6b 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.
7a Monaco: The legal basis is the CbC MCAA which was signed by Monaco on 2 November 2017.
7b Monaco: The Sovereign Orders and Ministerial Orders to implement CbC reporting requirements have been submitted to the Council of Government on 13 December 2017. It is expected that they will soon be officially signed by the Sovereign Prince and will subsequently be published.
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.
9 Luxembourg: a Grand-Ducal Regulation (“Réglement Grand Ducal”) is still expected which will list the jurisdictions with which Luxembourg will exchange CbC reports. However, rules are in place to require the filing of a CbC report by Ultimate Parent Entities in Luxembourg.