The Irish Revenue released a new Tax and Duty Manual on Country-by-Country Reporting (CbCR). The manual responds to some frequently asked questions on the interpretation of the CbCR legislations in Ireland.
Being part of Action 13 of the OECD/G20 BEPS project and the EU Commission’s Anti-Tax Avoidance Package, CbC Reporting applies to MNE Groups with consolidated group revenue of €70 Million or more in the immediately preceding fiscal year. An Irish tax resident constituent entity which is ultimate parent entity, surrogate parent entity or designated entity of such an MNE Group is required to file CbC Reports in Ireland with effect from 1 January 2016. Under some circumstances, an Irish tax resident domestic constituent entity which is neither an ultimate parent entity, a surrogate entity nor an EU designated entity of such an MNE Group may be required to file a CbC Report or an Equivalent CbC Report under the secondary reporting mechanism.
A CbC Report for an MNE Group must contain the following information in respect to each jurisdiction in which the MNE Group operates:
An Equivalent CbC Report is a country-by-country report, but only to the extent the information required to be included in that report is within the possession of, or is obtained or acquired by, a domestic constituent entity. Under secondary reporting mechanism, an Irish tax resident domestic constituent entity, whose parent has refused to provide it with all the information required to provide a full CbC report for the MNE Group, is required to include in the CbC Report:
All notifications must be made no later than the last day of the fiscal year to which the CbC Report/Equivalent CbC Report relates and must be made for each fiscal year. Notifications should be submitted electronically via ROS and follow the Step-by-Step Guide in Appendix III.
If errors are found in a notification already submitted to Revenue via ROS, users can refer Section III of the Step-by-Step Guide to replace the errors.
The Manual also clarifies other technical issues, including:
With the fast growth of China’s economy and the continuous improvement of the comprehensive strength of domestic enterprises, as well as the implementation of the “One Belt, One Road” policy, an increasing amount of Chinese enterprises are beginning to expand their global footprint and establish their presence in Europe.
TPA Global has developed a practical roadmap of 6 steps meant to guide CFOs in their Journey of rising above troubles to reach a situation of full control. These steps are presented in a series of short video clips (3-5 minutes):