The final regulations—Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016—reflect several amendments to the draft regulations published in October 2015, in particular that UK subsidiaries of foreign-parented groups will now be required to file a CbC report for the UK sub-group if the foreign parent is not required to file in its own territory (or HM Revenue & Customs does not receive the report from that tax authority). Read the final regulations.
This change will be of particular interest to U.S.-parented groups, since the U.S. CbC requirements are not expected to be effective until 2017.
As expected, the regulations will apply to multinational groups for accounting periods beginning on or after 1 January 2016.
The revenue threshold (based on the group’s consolidated revenue for the previous year) of £586 million has been replaced with the euro equivalent of €750 million.
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