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 high margin food products specifically to potential risks identified through the use of CbCR information.
Relevant Legislation
- Canada is one of 69 nations exchanging information, which helps the CRA to better risk assess multinationals for tax compliance.
- 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.
- 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.
- Scrolla The Gauteng education department says budget cuts delayed payments to service providers in its extended school nutrition programme.
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.
Public country-by-country reporting
The HK UPE may also voluntarily file a CbC Return for an accounting period beginning between 1 January 2016 and 31 December 2017. The Department will not use CbCR information as a substitute for a detailed transfer pricing analysis of individual transactions and prices based on a full functional analysis and a full comparability analysis. 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.
CbC reporting topics
This guide provides CFOs and tax professionals with a structured overview of Bahrain’s CbCR framework, including applicability, reporting obligations, submission process, penalties, and key resources. Gain insights into the latest political developments, including government decisions, policy changes, and key political figures shaping South Africa’s future. Our economic coverage delves into market trends, trade dynamics, and fiscal strategies, offering a clear view of the country’s economic status and its role in the global economy. We also bring you significant stories that define the social and cultural fabric of South Africa, highlighting issues and achievements that resonate both nationally and internationally. These additional transparency requirements will apply to any multinational company – whether European or not – that is currently significantly active in the EU. Penalties are provided in respect of matters such as failing to file CbC Returns and providing misleading, false or inaccurate information in CbC Returns.
- These rules aim to improve the transparency of payments made to governments all over the world by the extractive and logging industries.
- Oscar-winning actor Nicole Kidman and country music star Keith Urban have reportedly separated after 19 years of marriage.
- Bahrain has introduced Country-by-Country Reporting (CbCR) regulations in alignment with OECD BEPS Action 13 and its commitment to international tax transparency.
- 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.
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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.
Public Country-by-Country Reporting
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.
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.
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E.g. With respect to the financial year commencing on January 1st 2019 and ending by December 31st 2019, the CbC Report should be filed no later than December 31, 2020. CbC Reporting requirements come into effect for financial years starting on or after January 1st 2019. The UAE is committed to using information provided in CbC Reports in accordance with the permitted uses above. The OECD guidance on the implementation of CbC Reporting can be used to interpret the UAE CbC Reporting legislation to ensure a consistent and standard approach to CbC Reporting across all implementing countries.
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.
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.
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.
Forms & Instructions
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.
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. On 2 February 2018, the Inland Revenue (Amendment) Ordinance 2018 was enacted to empower the Chief Executive-in-Council (CE-in-C) to make an order for giving effect to the Multilateral Convention in Hong Kong. The CE-in-C made the Inland Revenue (Convention on Mutual Administrative Assistance in Tax matters) Order on 10 July 2018. A Hong Kong Entity should register a CbC Reporting Account under the CbC Reporting Portal for accessing the services provided thereunder.
