IEIM300100 - Country-by-Country Reporting: Directions relating to the information required to be included in Table 3 of the CbC report

The UK rules use many terms and definitions that are taken from the OECD guidance (link is external) and that guidance should be checked when completing a CbC report.

The following information is mandatory for all CbC reports beginning on/after 01/01/2020. We encourage MNE Groups to start applying this to CbC reports in advance of this.

Table 3 of the CbC report should be used to provide additional information that may help clarify the information provided in Tables 1 and 2 of the CbC report. In addition the Action 13 report and the additional OECD CbC guidance, details the following information that must be included within the CbC report:

Sources of data

The reporting entity is required to provide a brief description of the sources of data used in the preparing of the CbC report within Table 3, the Additional Information section. If a change is made in the source of the data from year to year, the reporting entity should explain the reasons for the change and its consequences in Table 3.

If the Main Business Activity of a constituent entity is Other

Where the main business activity of a constituent entity is indicated as “other” on Table 2 of the CbC report, an explanation of the activity of the constituent entity must be added to Table 3 of the CbC report. This applies to all constituent entities within the CbC report which have “other” as one of their main business activities.

Information required in respect of mergers

Mergers and acquisitions can change the CbC reporting requirements of an MNE Group. The OECD have published extensive guidance detailing a number of scenarios here :

http://www.oecd.org/tax/beps/guidance-on-country-by-country-reporting-beps-action-13.htm

Where an MNE Group acquires another MNE Group and the acquired MNE Group is no longer required to a file a CbC report, the following information is required in Table 3:

  • The succeeding MNE Group should detail the date of the acquisition

and

  • the following statement “The Acquired Group (Name) did not file a CbC report in any jurisdiction for the period xx/xx/xx.”