In response to the OECD Base Erosion and Profit Shifting (BEPS) project1 the UK (along with other OECD and G20 countries) introduced a country-by-country (CbC) reporting requirement2. The OECD Guidance can be found at Guidance on the implementation of CbC Reporting: BEPS Action 13 and HMRC guidance in their International Exchange of Information Manual starting at IEIM300010.
The CbC reporting initiative has been subject to a number of peer reviews to assess the success of the regime in continuing efforts to improve the taxation of multinational enterprises (MNEs) worldwide. See the OECD website for details of the 2020 review of the CbC reporting minimum standard.
It should also be noted that from April 2023, additional transfer pricing documentation records are required for certain UK entities that, together with one or more enterprises, constitute an MNE group that meets the CbC reporting threshold for a given period. For more information, see B4.159.
Qualifying entities for CbC reporting
The CbC reporting requirement applies to MNEs which meet the 'threshold amount' in an accounting period starting before and ending
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Web page updated on 17 Mar 2025 16:53