CbCr Services

Country-by-country reporting (CbCr) is one of four minimum standards under the OECD Base Erosion and Profit Shifting (BEPS) project that aims to improve transparency between multinational businesses and tax authorities, and to help identify aggressive tax avoidance.

Under country-by-country reporting, multinational groups with consolidated group revenue of 750 million or more, are required to report specified data on their international operations to their tax authority annually (“full reporting”)

A secondary aspect of the country-by-country reporting regime requires the separate business units of multinational groups (“MNEs”) to provide notification to the tax authority annually as a constituent entity if:

  • they are included in the consolidated financial statements of an MNE for financial reporting purposes, or would be so included if equity interests in such business unit were traded on a public securities exchange
  • they are excluded from the MNE’s consolidated financial statements solely on size or materiality grounds and
  • they are a permanent establishment of (a) or (b) for which separate financial statements are prepared