The UK country-by-country (CbC) regulations which implement the country by country reporting obligations under the OECD BEPS (Base Erosion Profit Shifting) Action Plan came into force last month.

CbC reporting applies to any multinational group with consolidated group revenue of €750m or more in an accounting period commencing on or after 1 January 2016.

Broadly, a UK subsidiary of foreign-owned groups must file a CbC report for the UK sub-group if the foreign parent is not required to file in its territory. The obligation also applies if HMRC does not expect to receive the report from that tax authority.

This legislation therefore imposes a secondary filing requirement if the foreign parent is not subject to CbC reporting. Thus the UK regulations will be of particular interest to any US-parented groups; in the US the CbC regulations are not expected to come into force until 2017.

In accordance with the OECD template, the CbC report will have to show for each tax jurisdiction in which the group does business the amount of revenue, profit before income tax and income tax paid and accrued; and their total employment, capital, retained earnings and tangible assets.