The UK Government has accepted a cross-party backbench amendment to Finance Bill 2016 which gives HM Treasury powers to introduce public country-by-country reporting (CBCR). The amendment allows, but does not compel, HM Treasury to bring forward regulations to require groups to include a country-by-country report in their published group tax strategy (assuming they are required to publish their tax strategy). For these purposes, a country-by-country report would be defined by the existing UK regulations, implementing the Action 13 proposals of the Organisation for Economic Co-operation and Development (OECD) to counter base erosion and profit shifting (BEPS), which require such a report to be filed with HM Revenue & Customs. No date for introducing public CBCR is stipulated. The requirement for certain groups to publish a tax strategy is to be introduced for all accounting periods commencing after Royal Assent to Finance Bill 2016 (expected around September 14).

A Tax Alert prepared by Ernst & Young UK, and attached below, provides additional details.

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ATTACHMENT

Full text of Tax Alert 2016-1511