The Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) (Amendment) Regulations, SI 2017/497, extend the country-by-country reporting obligations to include partnerships which are parent entities of multinational groups. This reflects changes in the OECD guidance recommending that partnerships should be reporting entities.
The regulations also make the following changes arising from amendments to the EU administrative cooperation directive:
a UK entity in a multinational group will be required to notify HMRC about which entity will file the group report and in which jurisdiction, together with names and unique taxpayer references for all of the multinational group’s UK entities; and
the top UK entity obliged to file under the local filing rules will be required to request information from the parent entity sufficient to file a full CbC report for the whole group and, if the parent refuses, notify HMRC of that fact and file a local report.
The first such notifications will be due on 1 September 2017 at the earliest. Thereafter, notifications are to be made by the end of the relevant reporting period.
The regulations also make a minor adjustment to align the UK’s local filing requirements with the OECD model. Local filing will only be required where the parent jurisdiction of the foreign multinational group has entered into an international agreement to exchange information, but has not made specific arrangements for country-by-country reporting.
These regulations come into force on 20 April 2017. HMRC has also published a tax information and impact note on the changes.
The Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) (Amendment) Regulations, SI 2017/497, extend the country-by-country reporting obligations to include partnerships which are parent entities of multinational groups. This reflects changes in the OECD guidance recommending that partnerships should be reporting entities.
The regulations also make the following changes arising from amendments to the EU administrative cooperation directive:
a UK entity in a multinational group will be required to notify HMRC about which entity will file the group report and in which jurisdiction, together with names and unique taxpayer references for all of the multinational group’s UK entities; and
the top UK entity obliged to file under the local filing rules will be required to request information from the parent entity sufficient to file a full CbC report for the whole group and, if the parent refuses, notify HMRC of that fact and file a local report.
The first such notifications will be due on 1 September 2017 at the earliest. Thereafter, notifications are to be made by the end of the relevant reporting period.
The regulations also make a minor adjustment to align the UK’s local filing requirements with the OECD model. Local filing will only be required where the parent jurisdiction of the foreign multinational group has entered into an international agreement to exchange information, but has not made specific arrangements for country-by-country reporting.
These regulations come into force on 20 April 2017. HMRC has also published a tax information and impact note on the changes.
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