Transcription of COUNTRY-BY-COUNTRY REPORTING GUIDELINES
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IRBM COUNTRY-BY-COUNTRY REPORTING GUIDELINES COUNTRY-BY-COUNTRY REPORTING GUIDELINES Published 01 January 2019 IRBM COUNTRY-BY-COUNTRY REPORTING GUIDELINES TABLE OF CONTENTS PAGE INTRODUCTION 1 OBJECTIVE 2 APPLICATION 2 WHAT IS A COUNTRY-BY-COUNTRY REPORT 3 FILING OBLIGATION 5 NOTIFICATION 7 CONFIDENTIALITY AND APPROPRIATE USE 8 TEMPLATE FOR COUNTRY-BY-COUNTRY REPORT 8 ANNEX A 14 GLOSSARY 17 IRBM COUNTRY-BY-COUNTRY REPORTING GUIDELINES 13 INTRODUCTION The COUNTRY-BY-COUNTRY REPORTING (CbCR) regulation was introduced in the Final Report on Base Erosion and Profit Shifting (BEPS) Action 13 published by the Organisation for Economic Co-operation and Development (OECD) in October 2015, as part of the three-tiered approach to transfer prici
including the tax jurisdiction of incorporation, where different from the tax jurisdiction of residence, as well as the nature of the main business activities carried out by that constituent entity. 4.3 The CbCR consists of three tables as set out in Annex A: (a) Table 1 provides an overview of the allocation of income, taxes and business ...
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