CbCR—Recent Developments in the U.K.
United Kingdom -- On March 30, 2017, the U.K. tax authority, Her Majesty’s Revenue and Customs (‘‘HMRC’’), published updated guidance regarding the country-by-country reporting (‘‘CbCR’’) requirements for multinational enterprises (‘‘MNEs’’).
The amendments consider updated guidance from the Organisation for Economic Co-operation and Development (‘‘OECD’’) and namely include: (i) Extending the original scope of CbCR requirements to partnerships (originally announced in August 2016); (ii) Requiring a U.K. entity with a local obligation to file a U.K. CbC report to ask for the information necessary to complete a full CbC report (for the whole group) and aligning the local filing requirements with the OECD model; and (iii) Introducing a requirement for a U.K. entity in each MNE group to communicate on an annual basis to HMRC which entity from within the MNE group will file the CbCR, in which jurisdiction they will file, and the names and unique taxpayer references of all the U.K. entities of the group.
This article originally appeared in the June 2017 edition of Bloomberg BNA.