Country-by-Country Reporting Guidance

 
Guidance and Resources Description

TD 9773 – Country-by-Country Reporting

Final regulations for annual country-by-country (CbC) reporting.

Revenue Procedure 2017-23 PDF

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

U.S. Model CbC CAA PDF (Treaty)

Model arrangement for the U.S. competent authority for the exchange of country-by-country reports (Updated 30-Jun-2017).

U.S. Model CbC CAA (TIEA PDF)

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 (Updated 30-Jun-2017).

U.S. Model CbC CAA (MAC) PDF

Model arrangement for the U.S. competent authority on the basis of the Convention on Mutual Administrative Assistance in Tax Matters for the exchange of country-by-country reports.

Jurisdiction Status Table Country-by-country reports are exchanged under competent authority arrangements. This table details their 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  PDF

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

Country-by-Country Reporting XML Schema User Guide (OECD)

OECD (2016), Country-by-Country Reporting XML Schema: User Guide for Tax Administrations and Taxpayers contains the standardized electronic format for the exchange of country-by-country reports between jurisdictions. It also explains the information required to be included in each reported data element.

Form 8975, Country-by-Country Report  PDF

Schedule A (Form 8975) Tax Jurisdiction and Constituent Entity Information PDF

Forms for country-by-country reporting.

Instructions for Form 8975 and Schedule A PDF

Instructions for country-by-country reporting.

Notice 2018-31: National Security Considerations with Respect to Country-by-Country Reporting PDF In consideration of the national security interests of the United States, this notice addresses modifications to the reporting requirement under §1.6038-4 with respect to certain U.S. multinational enterprise (MNE) groups.