Tax avoidance & CbCR - Functioning of CbCR

6 important questions on Tax avoidance & CbCR - Functioning of CbCR

Who imposed the CBCR

OECD

What are some main characteristics of CbCR

  • The EU adopted it as a part of ATAD
  • Applies to MNEs with a consolidated group revenue equal to or exceeding 750 million
  • Has to be filed in the parent entity's jurisdiction or by a surrogate parent
  • Publicly disclosed. Exemption possible of 5 years

What are some criticisms of CbCR?

  • Complexity
  • Data sensitivity
  • Uneven implementation
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What are the 3 key tables in CbCR reports

  1. Provides aggregate data for each jurisdiction in which the MNE operates.
  2. Lists all constituent entities of the MNE group and their main activities in each jurisdiction
  3. Includes any additional information the MNE wishes to provide to explain the data in the first two tables.

How is the revenue breakdown in CbCR reports?

  • Revenue from related party transactions
  • Revenue form unrelated party transactions

What type of financial information has to be showed in CbCR?

  • Aggregate date, financial information for each jurisdiction in which they operate
  • Exceptions where local consolidated data is accepted.

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