Legislation has been enacted that updates the Country-by-Country (CbC) reporting regulations as finalised in 2016 to take account of international developments.
The amendments can be found here.
Some of the amendments to the regulations had already been publicised, see for example the changes in relation to partnerships, however some increase the obligations on groups with a UK presence and/or bring forward the deadlines for providing the relevant information.
In particular the amendments to the legislation include:
- Extending the scope of the requirements to partnerships, such that they can now be reporting entities;
- Extending the UK ‘local filing’ requirements to oblige UK entities to file a whole group CbC report unless they have requested the required information and failed to obtain it;
- Introducing additional notification requirements such that all UK entities must tell HMRC about the UK or non-UK CbC filing unless another UK entity has already provided the required information on behalf of the other UK entities;
- Bringing forward the notification requirements - the deadline for notification is now the later of the end of the period to which the report relates or the 1 September 2017.
HMRC has published some basic guidance on the notification requirement in the International Exchange of Information Manual and has promised to publish full guidance in due course. A tax information and impact note has also been published here.
HMRC have said there is and will be no specific form for the notification, they would prefer the notification to be on a spreadsheet and a dedicated mailbox is available for filing. Where the Group has a Customer Relationship Manager (“CRM”), they have also requested a copy is provided to them.
If you would like to understand the changes in more detail or talk through how CbC Reporting will impact your business please contact Peter Barlow or your usual PwC advisor.