IEIM300090 | Country-by-Country reporting: UKEs – Directions relating to contents of the CbC reports

The UK rules use many terms and definitions that are taken from the OECD guidance and that guidance should be checked when completing a CbC report.

Where a top UK entity of the non-UK headed MNE group is required to file a CbC report, it must request the information it would need to file a CbC report for the whole group from its non-UK parent entity. If it receives the information it must file the CbC report by the deadline.

If the parent entity does not provide the information then the UK entity must notify HMRC in writing that the parent has not provided the information and the entity must file a UK CbC report by the deadline.

A UK CbC report is one that relates to the top UK entity and all entities of the MNE group that are shown in the UK entity’s Consolidated Financial Statements or would have been shown if it had been required to produce them. The content of the report is the same as for UPEs otherwise.

An example of the kind of evidence which would demonstrate that the UK entity has complied with the requirement to ask the parent for the information to file a full CbC report is an email exchange between relevant officers in each of the entities concerned.