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UK’s CbC draft regulations

HMRC has provided a technical consultation and explanatory memorandum for new regulations of UK’s country by country (CbC) reporting. Comments are due by 16 November 2015. For the details see

An interesting and debatable provision is section 9 of the technical consultation provision for information which is reproduced below. To the extent that a company is considered a ‘reporting entity’ the provision provides for a request of information that may reasonably be required within 14 days in a form specified by HMRC to substantiate the accuracy of the CbC report.

On the heels of the OECD release of the action items including Action 13 CbC reporting HMRC has released this documentation for consultation. However section 9 may be far-reaching in that there is no transparency into the intent of HMRC or purpose of such potential request.


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