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HMRC finalises CbCR guidance

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Relevant multinational groups with UK entities must notify HMRC by 1 September 2017 about the group’s first country-by-country report. This notification must include information on who will file the report and where, giving names and unique taxpayer references of all the group’s UK entities.

Detailed guidance on notification and reporting obligations is contained in HMRC’s International Exchange of Information Manual (IEIM), which was most recently updated on 10 August. The IEIM confirms that, where there are multiple entities within a group which would otherwise need to provide separate notifications, HMRC will accept a notification submitted by one of the entities, as long as it is clear it is sent on behalf of all the relevant entities.

The manual also makes clear that the definitive source is the G20/OECD guidance in the BEPS Action 13 final report. Questions not covered by the existing guidance should be referred to a group’s customer relationship manager at HMRC, if it has one, or to a dedicated HMRC email address if not.

The required format for country-by-country reporting will be via an XML schema. See

Issue: 1366
Categories: News