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Country-by-Country Reporting Guidance

Guidance and Resources Description

TD 9773 – Country-by-Country Reporting

Final regulations for annual country-by-country reporting.

Revenue Procedure 2017-23

Guidance for ultimate parent entities of U.S. multinational enterprise groups about filing a Form 8975, Country-by-Country Report, for early reporting periods. The revenue procedure discusses the timing and manner of these early filings.

U.S. Model CbC CAA (Treaty)

Model arrangement for the U.S. Competent Authority for the exchange of country-by-country reports

U.S. Model CbC CAA (TIEA)

Model arrangement for the U.S. Competent Authority on the basis of a Tax Information Exchange Agreement for the exchange of country-by-country reports

Jurisdiction Status Table The Country-by-Country Report will be exchanged under bilateral Competent Authority Arrangements. This table details agreement status by jurisdiction.   

Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 Final Report

OECD final report on transfer pricing documentation and country-by-country reporting.

Guidance on the Implementation of Country-by-Country Reporting: BEPS Action 13 

Additional OECD guidance on the global implementation of country-by-country reporting.

Country-by-Country Reporting XML Schema User Guide (OECD) The OECD CbC XML Schema User Guide contains standardized electronic format for the exchange of CbC Reports between jurisdictions. It also explains the information required to be included in each data element to be reported.

Form 8975, Country-by-Country Report
Schedule A (Form 8975), Tax Jurisdiction and Constituent Entity Information

Draft forms for country-by-country reporting.

Instructions for Form 8975 and Schedule A

Draft instructions for country-by-country reporting.


Page Last Reviewed or Updated: 22-Jun-2017