Country-by-Country Reporting (CbCR) is part of Action 13 of the Base Erosion and Profit Shifting (BEPS) initiative led by the Organisation for Economic Co-operation and Development (OECD) and the Group of Twenty (G20) industrialised nations.
Under CbCR, all large multinational enterprises (MNEs) are required to prepare a Country-by-Country (CbC) Report with aggregate data on the global allocation of income, profit, taxes paid and economic activity amongst the various tax jurisdictions in which they operate. As per BEPS Guidance, it is recommended that the MNE Groups be compelled to comply with CbCR when the group consolidated turnover exceeds the OECD threshold under the respective country’s local CbCR Regulations.
While CbCR has enabled tax authorities to better assess transfer pricing risks, it has imposed new compliance burdens on large MNE groups.
At MBG Corporate Services, our worldwide network of advisors combines international experience with local tax knowledge to guide you through and manage the CbCR process. From providing a thorough and detailed understanding of the CbCR regime as applicable and the penalties for non-compliance to assisting you on the filings globally, we have you covered.
• CbCR impact and applicability assessment
• Collection and analysis of country-by-country data on revenues, employees, assets, profit, stated capital, taxes, economic activity and other applicable financial parameters
• GAP assessment & health check of CbCR filings versus other compliances such as Economic Substance Regulations (ESR) and Transfer Pricing (TP)
• Identification of risks
• Management review and discussion
• Preparation & filing of CbCR notification & report, as applicable
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