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.
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.
1. In Brazil, local filing was suspended for reporting fiscal years commencing in 2016, subject to conditions.
2. In the People's Republic of China, local filing was suspended for reporting fiscal years commencing in 2016.
3. Voluntary parent surrogate filing is or was available for earlier fiscal years.
4. Local filing has been suspended.
5. 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.
6. 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.
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