On March 30, 2017 the UK HM Revenue & Customs (HMRC) published a policy paper titled “Amendments to Country By Country reporting 2017” as well as an updated policy paper: “Country by country reporting”, which was initially published on February 26, 2016.
Policy paper “Amendments to Country By Country reporting 2017”
This policy paper provides the following description of the measure:
“This new measure updates The Taxes (Base Erosion and Profit Shifting) (country-by-Country Reporting) Regulations 2016 (the 2016 Regulations) which require MNEs to provide HM Revenue and Customs (HMRC) with information about global activities, profits and taxes. The updates are to take account of international developments including by:
· extending the original statutory requirements to partnerships, this amendment was announced in August 2016
· requiring a UK entity with an obligation to file a UK Country by Country (CbC) report to ask for the information necessary to complete a full CbC report and making a minor change to align the “local filing” requirements with the OECD model
· introducing a requirement for a UK entity in each MNE group to tell HMRC, annually, which entity in the MNE group will file the CbC report and where and provide the names and unique taxpayer references for all of the MNE group’s UK entities”
It is also worth noting that the measure introduces a requirement for the top UK entity required to file under the local filing rules to ask its parent entity for the information it would need to be able to file a full CbC report for the whole group. If the parent entity refuses the UK entity must tell HMRC of the refusal and file a CbC report covering all entities within the sub group of which it is head.
Furthermore this policy paper discusses a.o. the following subjects:
· Operative date
· Current law
· Proposed revisions
Click here to be forwarded to the policy paper titled “Amendments to Country By Country reporting 2017” as available on the website of the UK Government.
Updated policy paper “Country by country reporting”
Also on March 30, 2017 the HRMC published an updated policy paper “Country by country reporting”. This policy paper was first published on February 26, 2016. Topics discussed in this policy paper include a.o.:
· General description of the measure
· Detailed proposal
o Operative date
o Current law
o Proposed revisions
Click here to be forwarded to the policy paper titled “Country by country reporting – updated” as available on the website of the UK Government.
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