Readers' forum: What to report?

30 October 2018

Issue: 4670 / Categories: Forum & Feedback

CbC filing requirement for UK subsidiary.

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 FA 2016 rules? According to my reading of the CbC reporting requirements in HMRC’s International Exchange of Information Manual such a subsidiary – and one that is not a top UK entity preparing consolidated financial statements – does not fall within the definition of a ‘UKE’.

Query 19 255– Susan.

Reply by Christopher Lallemand Mazars LLP

Identifying whether the group has a ‘UK entity’ is important.

Finance Act 2015 s 122 introduced a power for the Treasury to make regulations for implementing the OECD’s CbC reporting requirements. These are set out in SI 2016/237 which was updated by SI 2017/497 to include notification requirements. The regulations apply to multinational enterprises (MNEs) that meet a consolidated turnover threshold of €750m...

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