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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 10 January 2019

A B C D F G H I J K L M N P Q 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)?

Andorra   Not required 1 January 2018 1 January 2018   No
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
Bahamas     1 January 2018 No N/A   No
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 1 January 2016 No N/A N/A
Chile Not required   1 January 2016 No N/A N/A
China (People's Republic of)

1 January 2016

1 1 N/A
Colombia

 1 January 2016

1 January 2016
No N/A
Costa Rica Not required 1 January 2017 No 1 January 2017 N/A
Côte D'Ivoire   1 January 2018 No N/A No No
Croatia   1 January 2016   1 January 2017 N/A
Curaçao     1 January 2018 1 January 2018 Yes5
Czech Republic   1 January 2016 1 January 2017 N/A

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)?

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 1 January 2017

N/A

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)   Not required 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 201611 N/A
Indonesia Not required 1 January 2016 1 January 20168
No N/A
Ireland     1 January 2016 1 January 2016 N/A
Isle of Man     1 January 2017  1 January 2017 Yes
Israel  2   2
To be advised To be advised To be advised To be advised  To be advised
Italy     1 January 2016  1 January 2016  N/A

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)?

Japan   1 April 2016 1 April 20163 Yes
Jersey   1 January 2016 1 January 2016 N/A
Kazakhstan Not required 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 Yes
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
Monaco 7a 7b 1 January 2018 No N/A Yes No
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 2018 1 January 2018 Yes
Pakistan10   1 January 2016 1 January 2017 To be confirmed
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

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)?

Qatar   1 January 20179a To be advised9b To be advised9b
No
Romania   1 January 2016 1 January 2017 N/A
Russian Federation  6a 1 January 2017 1 January 2017 Yes6b
Senegal   1 January 2018 1 January 2018 Yes
Singapore   1 January 2017  Not yet introduced N/A  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
Sri Lanka Would be effective from  1st April 2018 1 April 2019 Year of assessment 2018/2019 N/A
Sweden   1 January 2016 1 January 2016 N/A
Switzerland

1 January 2018 1 January 2018 Yes
Turkey  4 To be advised
To be advised To be advised To be advised
No
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

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.

Israel: Legislation to introduce a CbC reporting requirement is currently in draft form.

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. 

9a Qatar: For fiscal years commencing in 2017, a CbC report is not required to be filed in Qatar if an MNE files a CbC report in another jurisdiction via a surrogate parent entity. UPEs resident in Qatar will be required to file a CbC report in Qatar for fiscal years commencing on or after 1 January 2018.

9bQatar: Local filing in Qatar is suspended until a future date, to be announced.

10 Pakistan: Information based on the peer review report published 23 May 2018.

11 India: For fiscal years ending up to 28 February 2018, the filing deadline for local filing purposes is 31 March 2019.

 

Further information

 

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