Constituent entities may be required to make CbC notifications by the end of the accounting period.
The OECD’s model legislation for Country by Country (CbC) reporting includes a notification requirement for constituent entities, essentially informing their local tax authorities where the group CbC reporting will be filed. Implementation of this requirement differs between countries. There is no standard mechanism to notify, but the deadline can be as early as the end of the accounting period, 31 December 2016, for groups with a calendar year end. The UK deadline is 12 months after the year end, although HMRC have not yet announced how to make the notification.
This is a rapidly evolving area, and some countries have already deferred the notification during the transition year. It is important however that groups are aware of this additional compliance requirement and add it to their global compliance calendar.
The KPMG Action 13 implementation summary is updated weekly and provides a useful overview.
For more detailed information, please speak to your local KPMG contact or one of the contacts listed in this article.
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