United Kingdom - UK authorities address country-by-country reporting  

May 16: HM Revenue & Customs (HMRC) and HM Treasury (HMT) recently met with a cross section of global companies to discuss the proposed revised draft of the OECD country-by-country (CbyC) reporting template.

Some of the latest developments are:

  • Revenues need to be split between related and unrelated parties
  • Withholding taxes are to be included as part of the taxes paid figure
  • The current tax accrual is intended to exclude deferred taxes (i.e., more akin to the current year corporate income tax charge ignoring prior year adjustments)

Also, with respect to the entity list, there is an expanded list of activity types that can be used.

The HMRC and HMT discussion focused on practical aspects of compliance, including the practical challenges of preparing country consolidations rather than aggregations; potential disconnect between the reported figures on the template and local tax return figures when data is gathered from central consolidation systems; and further clarification needed around definitions.

The next steps in the consultation process will be focusing on the details of the guidance that will accompany the template.

Read a May 2014 report [PDF 848 KB] prepared by the KPMG member firm in the UK: Weekly Tax Matters (16 May 2014)

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