Country-By-Country Reporting: A Collection of Expert Analysis


The IRS issued final “country by country reporting” (CBCR) regulations in late June, giving US-based multinationals a clearer picture of the complex new reporting regime that will apply to all large corporate taxpayers with foreign operations and annual operating revenue of $850M or more.


The OECD’s “base erosion and profit shifting” initiative included a recommendation that all member countries implement CBCR rules. Under such rules, a parent of a multinational group will be required to provide country-specific information on the origin of revenues and pre-tax income, as well as the amount of taxes paid and earnings retained. Reporting will also be required on the number of employees and the amount of tangible assets and capital, by jurisdiction. Although the reports will not be public, the tax authority in the jurisdiction of filing (typically, the parent’s “home” country) will share the information with the tax authorities in other countries in which the multinational does business.