Country-by-Country Reporting Notification
For U.S. ultimate parent entities of multinational enterprises (“MNEs”) that are filing Internal Revenue Service Form 8975 and Schedules A (Form 8975) (“Country-by-Country Report”) for the year ending December 31, 2017, the Country-by-Country Report will be due with a timely filed U.S. income tax return for 2017. The tax administrations of jurisdictions in which the MNE has constituent entities, however, will generally need to be notified of which entity will be filing the Country-by-Country Report and with which tax administration by December 31, 2017. For example, HM Revenue and Customs (“HMRC”) of the United Kingdom has a template which can be completed and e-mailed to a dedicated mailbox by year end to provide notification. Other tax administrations may have portals on their websites for providing the information.
U.K. Tax Strategy
Large MNEs with a U.K. presence and calendar fiscal years will be required to publish their U.K. tax strategies by December 31, 2017. They must be made available to the public through, for example, the company’s website. Please see attached summary from my August 2017 Transfer Pricing Update for more information.
2017 Transfer Pricing Deadlines
As we approach the end of the year, here are a couple deadlines to be aware of: