The person authorized to register a CbC Reporting Account for the entity has to possess an e-Cert (Organisational) with AEOI Functions for authentication purposes. More information about the application for e-Cert (Organisational) with AEOI Functions can be found in the website of the Hongkong Post Certification Authority. The deadline for filing a CbC Return is 12 months after the end of the relevant accounting period or the date specified in the assessor’s notice, whichever is the earlier. The requirements for filing a CbC Return, which includes a CbC Report, only apply to a MNE Group whose annual consolidated group revenue reaches the specified threshold amount, i.e. CbCR notifications must be submitted no later than the last day of the financial reporting year of the MNE.
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Based on the existing UAE laws and international tax treaties, an entity should be considered as a tax resident in the UAE if it is incorporated or created under the laws of UAE or has its place of effective management therein. A number of terms used in these FAQs are defined in the UAE CbC Reporting Legislation, including, e.g. “country-by-country report”. Whilst these FAQs provide further information to assist with the interpretation of some of these terms, the reader is referred to the UAE CbC Reporting Legislation for a full definition of all relevant terms. In the UAE, CbCR requirements are applicable to the UAE-headquartered MNE Groups with ‘financial reporting years’ starting on or after January 1st 2019.
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The Department will not use CbCR information, by itself, to assess or reassess taxpayers’ income for the purposes of the Inland Revenue Ordinance. The content provided on this webpage does not constitute legal or tax advice in respect of the matters set out herein. The CbC report should be filed within 12 months from the end of the reporting year of the MNE Group.
- The UAE tax resident entity, which is an Ultimate Parent Entity of the MNE Group subject to the CbC Reporting Legislation as clarified under question 9 above.
- The Multilateral Convention on Mutual Administrative Assistance in Tax Matters (the Multilateral Convention) will be the main platform for Hong Kong to exchange CbC Reports with other jurisdictions.
- CbC Reporting is part of Action 13 of the Base Erosion and Profit Shifting (BEPS) initiative led by the Organization for Economic Co-operation and Development (OECD) and the Group of Twenty (G20) industrialized nations.
- The EITI is a voluntary initiative promoting public awareness of how countries manage their oil, gas and mineral resources.
Public Country-by-Country Reporting
It should be noted that there are some differences between the OECD Model legislation and the UAE CbC Reporting Legislation. The challenging global context has not deterred our commitment to the Just Energy Transition Partnership, writes the International Partners group. Alexander Forbes has been interdicted from paying former deputy president David Mabuza’s R44.7-million pension to his widow, Patience Mnisi.
The information will not be taken as conclusive evidence that a MNE Group is engaged in other forms of BEPS. In addition, Chinese Mainland and Hong Kong have agreed to ride on a bilateral arrangement made pursuant to the Chinese Mainland-Hong Kong CDTA to undertake exchange of CbC reports. CbC Reports are to be exchanged automatically between tax administrations under relevant exchange arrangements. For a list of all bilateral exchange relationships that are currently in place for the automatic exchange of CbC reports between tax authorities, please refer to the OECD web page on Activated exchange relationships for Country-by-Country reporting.
- The UAE is committed to using information provided in CbC Reports in accordance with the permitted uses above.
- These rules aim to improve the transparency of payments made to governments all over the world by the extractive and logging industries.
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- CbCR information on its own will not constitute conclusive evidence that transfer prices are or are not appropriate, and will not be used to propose transfer pricing adjustments based on a global formulary apportionment of income.
- Late filing, not filing, making false statements or omitting information from returns may result in penalties.
Paragraph 233.8(3)(b) of the Income Tax Act concerns the filing obligations of constituent entities in Canada and refers to the reporting requirements of the ultimate parent entity in the jurisdiction of residence. The CbC Report requires aggregate tax jurisdiction-wide information relating to the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which the MNE Group operates. CbC Reporting is part of Action 13 of the Base Erosion and Profit Shifting (BEPS) initiative led by the Organization for Economic Co-operation and Development (OECD) and the Group of Twenty (G20) industrialized nations. The purpose of CbC Reporting is to eliminate any gap in information between the taxpayers and tax administrations with regards to information on where the economic value is generated within the MNE Group and whether it matches where profits are allocated and taxes are paid on a global level. With the country-by-country Directive, multinational enterprise groups with global revenues exceeding EUR 750 million will publish, starting in year 2026, how much corporate tax they pay in each Member State as well as in non-cooperative jurisdictions for tax purposes. The reports will include contextual information per country in addition to the amount of corporate income tax, such as the nature of activities, the list of subsidiaries, turnover, number of employees, retained earnings, and profit before tax.
Bahrain has introduced Country-by-Country Reporting (CbCR) regulations in alignment with OECD BEPS Action 13 and its commitment to international tax transparency. The Ministry of Industry and Commerce (MOIC) is the regulatory authority overseeing CbCR compliance in Bahrain, ensuring that multinational enterprises (MNEs) meet their reporting obligations. Country-by-country reporting differs from regular financial reporting in that companies have to publish information for every country they operate in rather than providing a single set of information at global level. The EU requires companies in the extractive and logging industries to report on their payments to governments, and is working to promote tax transparency among multinationals.
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For example, CbCR information (such as the details of constituent entities) may be used as the basis for making enquiries into tax matters identified using other data sources or arising during the course of a tax audit or investigation. The reason for this is that XML documents can be validated and provide a common medium for exchange between the jurisdictions who have introduced CbC reporting requirements. In this regard, the Department has developed a data schema in XML which is based on the CbC XML Schema issued by the OECD. In respect of a Reportable Group, the primary obligation of filing a CbC Return is on the ultimate parent entity (UPE) resident in Hong Kong (HK UPE) and not on any other constituent entities resident in Hong Kong (Hong Kong Entities). The HK UPE is required to file a CbC Return for each accounting period beginning on or after 1 January 2018.
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Every Hong Kong Entity is required to make a notification containing information relevant for determining the obligation for filing a CbC Return within 3 months after the end of the relevant accounting period. For a Reportable Group with more than one Hong Kong Entity, a Hong Kong Entity is not required to make a notification provided that it is not the entity which is to file a CbC Return and another Hong Kong Entity has already made the notification. In practice, an assessor will give a filing notice to an entity which has made such notification or any other entity which is considered to be obliged to file a CbC Return. Guidance for ultimate parent entities of U.S. multinational enterprise groups about filing a Form 8975, Country-by-Country Report, for early reporting periods. In June 2018, Canada joined its international partners in the first exchanges of information on the revenue, profit, tax and accumulated earnings information of multinational enterprises. The EU aims to enhance the transparency on corporate income tax paid by large companies, with a view to foster greater corporate accountability, enable better informed public debate and contribute to maintain trust in the fairness of national tax systems.
Any breach of appropriate use of CbCR information will be disclosed as required under relevant exchange arrangements, and any inappropriate tax adjustment based on CbCR information will be conceded in any relevant competent authority proceeding. The CbC report is a form that multinational enterprise groups are required to complete and file annually to provide information of their global operations in each tax jurisdiction where they do business. Information obtained from the CbC reports is secure and will be used for high level transfer pricing risk assessment, the assessment of other base erosion and profit shifting (BEPS) related risks and for statistical and economic analysis. Permanent establishment data should be reported by reference to the tax jurisdiction in which the permanent establishment is situated and not by reference to the tax jurisdiction of residence of the entity of which it is a permanent establishment. Information reported by reference to the residence tax jurisdiction of the entity of which it is a permanent establishment should exclude financial data related to the permanent establishment.
Accordingly, for the financial reporting year starting on January 1st 2019, the CbC report must be submitted by December 31st 2020 at the latest. For anyone interested in African affairs, economists, political analysts, or cultural enthusiasts, NewsNow’s feed on South Africa is an essential source. We compile the latest news, expert analysis, and comprehensive reports from a range of high margin food products credible sources, ensuring a detailed and nuanced perspective on South Africa’s ongoing developments. Latest news on and from South Africa, including current affairs, politics, economics, and other big stories concerning the country on the southernmost tip of Africa. With NewsNow’s dedicated feed, get comprehensive updates that capture the pulse of this vibrant nation.
Enterprises will also have to disclose similar information, globally, on the basis of the business they conduct outside the EU. However, the Department may use CbCR information in planning a tax audit or investigation, or as the basis for making further enquiries into the MNE Group’s transfer pricing arrangements or other tax matters, in the course of an audit. There is also no requirement that these enquiries must relate specifically to potential risks identified through the use of CbCR information.
Scrolla The Gauteng education department says budget cuts delayed payments to service providers in its extended school nutrition programme. National school meals continue, but the extra provincial programme feeding children in fee-paying schools has run into financial problems. These rules aim to improve the transparency of payments made to governments all over the world by the extractive and logging industries. The implementation framework for CbC reporting in the Hong Kong Special Administrative Region (Hong Kong) is provided under the Inland Revenue (Amendment) (No. 6) Bill 2017 (the Bill). The Bill was published in the Gazette on 29 December 2017 and was passed by the Legislative Council on 4 July 2018.
The Commission has also proposed a new directive that will require large multinational companies to publish country-by-country information on where they make their profits and where they pay tax. A HK Reportable Group should take note that whether this voluntary filing of the CbC Return can relieve its Local CbC Filing obligation in a jurisdiction would depend on the CbC reporting requirements of that jurisdiction. Model arrangement for the U.S. competent authority on the basis of a tax information exchange agreement for the exchange of country-by-country reports (updated June 30, 2017). This filing requirement is part of a global initiative by the Organisation for Economic Cooperation and Development (OECD)/G20 to enhance transparency for tax administrations.
Public country-by-country reporting
Model arrangement for the U.S. competent authority on the basis of the Convention on Mutual Administrative Assistance in Tax Matters for the exchange of country-by-country reports. Model arrangement for the U.S. competent authority for the exchange of country-by-country reports (updated June 30, 2017). If separate entity statutory financial statements are used as the basis for reporting, all amounts should be translated to the stated functional currency of the MNE Group. The applied rates should be stated in the Additional Information section (Table III) of the CbC Report.