Country by country reporting – first reports are imminent

HMRC has published the XML schema guidance for the format that companies must use when complying with their obligations to file country by country reports. It is a minimum standard under the BEPS Action Plan for such reports to be submitted.

These reports are just sent to tax administrations and are not in the public domain.

For accounting periods beginning on or after 1 January 2016 UK resident parent companies of groups with turnover in excess of €750m have to submit relevant data to HMRC. It is anticipated that this will affect 300 parent companies of these groups. In addition similar data will be required from about 100 UK resident subsidiaries, or permanent establishments, of non UK headed multinational groups.

HMRC has just published a guide Check if you must send a country-by-country report so that companies can check whether they have to make a report. They should notify HMRC by 1 September 2017 if they are required to make a report. The reports themselves must be submitted within 12 months of the end of the relevant accounting period.

The information in the Country by Country report will cover:

  1. Tax jurisdiction
  2. Revenue from related parties
  3. Revenue from third parties
  4. Total revenue
  5. Profit before tax
  6. Corporate income tax paid (including withholding tax)
  7. Current year corporate income tax accrued
  8. Stated capital
  9. Accumulated earnings
  10. Tangible fixed assets, excluding cash and cash equivalents
  11. Employees

There were some changes to the original Regulations including the extension of the reporting requirement to partnerships which we reported on in April 2017.

OECD keeps a running total of those countries that have signed up to country by country reporting, and introduced the necessary domestic legislation, which you can view on their website Country-Specific Information on Country-by-Country Reporting Implementation

  • Is the notification date above correct?  The Regulations seem to say "later of end of period being reported on and 1 September 2017" so for a 31 October year end group wouldn't the first notification be required by 31 October 2017?