The Internal Revenue Service has created a new section on its IRS.gov website dedicated to information on the Country-by-Country Reporting rules of the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting project, which aims to discourage tax avoidance by multinational companies.
The new Country-by-Country Reporting web pages offer some background information, along with frequently asked questions and other resources, including a list of jurisdictions that have Competent Authority Arrangements with the U.S. government.
Country-by-Country Reporting is part of Action 13 of the OECD’s Base Erosion and Profit Shifting action plan, also known as OECD BEPS. CbC reporting aims to improve transparency by providing tax authorities with information to help them conduct high-level transfer pricing risk assessments.
As part of that effort, U.S. parent companies of multinational enterprises with $850 million or more of revenue in the relevant preceding annual reporting period are supposed to file Form 8975 and Schedules A (Form 8975) (also known as the "CbC Report") with their annual income tax return. The CbC Reporting web pages contain information and links to Guidance and Resources for U.S.-based multinationals on country-by-country reporting, including the final regulations, Rev. Proc. 2017-23 on filing for early reporting periods, and the forms and instructions.
The CbC Reporting website also includes a periodically updated Country-by-Country Reporting Jurisdiction Status Table listing the countries that have signed competent authority arrangements for CbC Reporting with the U.S. For those countries that have agreed for the text to be made public, links to the text are also included.
In addition, the CbC Reporting pages also provide:
• A list of CbC Reporting frequently asked questions (FAQs) along with a link where comments and questions can be submitted to the IRS CbC Reporting Mailbox (mailto:firstname.lastname@example.org). The IRS plans to read the comments and questions and update its CbC Reporting FAQs when needed.
• A link to subscribe to the CbC Reporting Newsletter, which the IRS will email periodically with updates and information on the topic.
• Instructions for Reporting Unauthorized Use for telling the IRS about any suspected unauthorized disclosure or misuse of information that has been exchanged with a tax treaty or Tax Information Exchange Agreement partner.
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