New queries, issue 4667

On report

CbC filing requirement for UK subsidiary of non-UK MNE.

Does a company that is a standalone UK subsidiary of a non-UK headed parent multinational enterprise group need to file a country-by-country (CbC) report under the new Finance Act 2016 rules?

According to my reading of the CbC reporting requirements in HMRC’s manual on international exchange of information a UK subsidiary of a foreign-headed multinational enterprise group that has no subsidiaries of its own and is not a top UK entity preparing consolidated financial statements does not fall within the definition of a ‘UKE’. It is therefore outside the scope for filing a CbC report.

I should be interested to know Taxation readers’ views and comments on this.

Query 19 255– Susan.

Retirement fund

Separating business and properties into two companies.

Our clients a husband and wife jointly own a limited...