HMRC publishes guidance on country-by-country reporting

HM Revenue & Customs has published guidance on which companies must produce a country-by-country report under The Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016. The guidance includes details on when and how to file the report and the notifications that need to be made.

The UK follows the country-by-country reporting requirements of the Organisation for Economic Cooperation and Development. The report must set out specified information including revenue, profit before income tax and income tax paid in each tax jurisdiction in which the group does business.

Who should file a report?

A report will need to be filed with HMRC by any UK resident ultimate parent company of a multinational group with a consolidated revenue of €750 million or more during the relevant accounting period.

In some circumstances the UK entity may not be the ultimate parent of the group, for example, where the ultimate parent is based in a country that doesn’t require the filing of a country-by-country report. Notifications If a group needs to file a report, a notification must be made to HMRC at the end of the group’s reporting period.


Once the notification to HMRC has been made, a registration form will need to be completed. The guidance states that the registration service will be available soon.


The report must be filed within 12 months from the end of the relevant reporting period.