US IRS Now Accepting CbC Reports
The US Internal Revenue Service (IRS) has begun accepting country-by-country (CbC) reports from multinational corporations.
In June 2016 the IRS issued final regulations requiring CbC reporting by the ultimate parent entity of a multinational enterprise (MNE) group with revenue of USD850m or more in the preceding accounting year. The first deadline for the filing of the CbC report is October 16, 2017.
The IRS announced on August 11, 2017: “Parent entities of US MNE Groups with USD850m or more of revenues in a previous annual reporting period can now file Form 8975, CbC report, with their annual income tax return. Form 8975, and attached Schedules A, will report a US MNE Group’s income, taxes paid, and other indicators of economic activity on a CbC basis.”
The CbC report is one element of a new three-tiered standardized approach to transfer pricing documentation as proposed by the OECD in Action 13 of the base erosion and profit shifting project.
