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Country-specific information on Country-by-Country reporting implementation

 

 

Country-by-Country reporting requirements in Inclusive framework member jurisdictions

The table below contains information on the domestic legal frameworks for Country-by-Country (CbC) reporting around the world. It 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. This table contains the information received from members so far and will be updated as Inclusive Framework members continue to finalise their CbC reporting frameworks.

 

Disclaimer: The information in this table merely confirms whether these elements are present in the relevant jurisdiction's law or administrative practice. In order to confirm whether the implementation of any particular element by a jurisdiction is consistent with the BEPS Action 13 minimum standard, please refer to the latest BEPS Action 13 peer review of that jurisdiction by the Inclusive Framework on BEPS.

Footnotes

1. In Brazil, local filing was suspended for reporting fiscal years commencing in 2016, subject to conditions.
2.The British Virgin Islands has published guidance to suspend local filing pending legislative changes to remove the requirement
3. In the People's Republic of China, local filing was suspended for reporting fiscal years commencing in 2016.
4. Voluntary parent surrogate filing is or was available for earlier fiscal years.
5. Local filing has been suspended.
6. In Qatar, ultimate parent entities are in principle required to file a CbC report for reporting fiscal years commencing on or after 1 January 2017. However, for reporting fiscal years commencing before 1 January 2018 this obligation is waived where the MNE Group files a CbC report in another jurisdiction through a surrogate parent entity, subject to conditions. 7.An ultimate parent entity resident in Viet Nam should prepare a CbC report within 90 days after the end of the reporting fiscal year. In all cases, a CbC report should be filed within 15 working days of receiving a request from the tax administration.
8. Viet Nam does not apply local filing based on the BEPS Action 13 minimum standard. However, if a resident entity is a member of an MNE Group and the ultimate parent entity of that MNE Group is required to file a CbC report in its jurisdiction of residence, domestic law in Viet Nam provides that the resident entity should obtain a copy of that CbC report by the date when its income tax return is due and be prepared to provide this to the tax administration on request, subject to exceptions.

 

Country-by-Country reporting notification requirements

The table below provides an overview of which Inclusive Framework members have introduced requirements for constituent entities in MNE Groups to notify the jurisdiction's tax administration of whether a CbC report will be filed. This includes basic information such as who is subject to the requirement, the deadline for notifications and the format to be used.

 

Disclaimer: This table is based on the latest information provided by each jurisdiction to the OECD. While this is a useful tool to allow MNE Groups to identify potential notification requirements in jurisdictions where they have constituent entities, the decision as to whether or not a notification is required, and the conditions attached to any notification, must be based on an MNE Group's own interpretation of each jurisdiction's law and/or guidance. Any questions concerning a particular jurisdiction's notification requirements should be referred to the tax administration or other relevant body in that jurisdiction.

 

Further information

 

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