UK: Preparing for country-by-country reporting

Country-by-country reporting in UK

For accounting periods starting on or after 1 January 2016, multinationals with a UK tax resident ultimate parent with consolidated group revenues above the sterling equivalent of €750 million in the previous period (converted at the average exchange rate for that period) will be required to submit an annual country-by-country (CbC) report for the global group to HM Revenue & Customs (HMRC) within 12 months of the year-end

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The UK rules, in a change from the original draft, provide that groups with a foreign parent in a country that does not introduce CbC reporting or does not have an effective exchange mechanism with the UK will have a requirement to file a “UK CbC report” with HMRC for the UK sub-group unless certain exceptions apply.   Broadly, the exceptions apply when a group company has filed a global CbC report either in a territory with an effective exchange agreement with HMRC or in the UK under the voluntary surrogate mechanism. There are notification requirements that need to be complied with before the filing deadline.  

A recurring question is "what needs to be done to prepare" for CbC reporting?  In general, companies need to be determining whether they are in scope of the UK rules and / or other countries rules, determining their strategy for data collection and reporting, doing dry-runs and risk assessing the data.


Read a March 2016 report prepared by the KPMG member firm in the UK: Country-by-country reporting  

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