A CbCR Notification should be distinguished from a Country by-Country (CbC) Report. A CbC Report requires aggregating tax jurisdiction-wide information relating to the global allocation of income, taxes paid, and certain indicators of the location of economic activities among tax jurisdictions in which the group operates. The primary obligation of filing a CbC Report is on the UPE/Surrogate Parent Entity (SPE).
The CbC Report is to be exchanged automatically between tax administrations under relevant exchange arrangements. For tax periods before January 1, 2019, Hong Kong has exchange arrangements with 11 jurisdictions, as of January 29, 2019. These are France, Guernsey, Ireland, Japan, Jersey, Korea, Malta, Netherlands, New Zealand, South Africa, and the United Kingdom.