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.
Navigating Q4 2025: Essential Income Tax Accounting Insights
January 20, 2026
Update on income tax accounting developments summarizing key 2025 4Q changes and highlighting practical considerations for multinational companies.
2026 Bonus and LTIP Target Setting Toolkit
January 19, 2026
The fourth edition of our target-setting toolkit supports remuneration committees and reward teams with this challenge by providing a range of market reference points for profit-based performance targets within both the annual bonus and the long-term incentive across the FTSE 100, 250 and Small Cap.
India Tax Alert | Supreme Court Redefines Tax Treaty Protection: GAAR Trumps DTAA in Indirect Transfers
January 16, 2026
In its landmark judgment dated January 15, 2026, in the case of Tiger Global International III Holdings and others, the Honorable Supreme Court (SC) has set aside the Delhi High Court’s (HC) decision dated August 28, 2024.
India Tax Alert | Supreme Court Clarifies Taxability on Amalgamation: The “Commercial Realizability” Test
January 13, 2026
In a landmark ruling, the Supreme Court has introduced the “commercial realizability” test to assess taxability in share substitution cases, holding that freely marketable shares with definite commercial value may give rise to taxable business income.