IEIM300160 - Country-by-Country reporting: Which countries will HMRC exchange CbC reports with?
The UK rules use many terms and definitions that are taken from the OECD guidance and that guidance should be checked when completing a CbC report.
CbC reports will be shared automatically with tax authorities in those countries named in the report and with which the UK can exchange in accordance with international agreements governing the exchange of information. HMRC has committed to exchange these reports within 15 months of the end of the period covered by the report (18 months for the first period). This means that a report for the year ended 31 December 2016 which is filed by the deadline of 31 December 2017 will be exchanged with relevant tax authorities by 30 June 2018. For the following year 31 December 2017 the exchange will take place by 31 March 2019. HMRC will not be notifying business of when the exchange actually takes place.
Countries with which the UK will exchange CbC reports can be found here:
http://www.oecd.org/tax/beps/country-by-country-exchange-relationships.htm
There are currently no countries where HMRC has determined exchange arrangements are not working effectively. Details of any change to this will be shown here.
International agreements governing the use and exchange of CbC reports require tax authorities to maintain the confidentiality of the information and data supplied on the reports.