U.S. multinational enterprises

 

Parent entities of U.S. multinational enterprise (MNE) groups with $850 million or more of revenue in a previous annual reporting period file Form 8975, Country-by-Country ReportPDF. Form 8975 is used to report a U.S. MNE group’s income, taxes paid, and other indicators of economic activity on a country-by-country basis.

Form 8975 Country-by-Country Report filing rules

  • Must be filed for the U.S. MNE group’s first reporting period in the tax year that starts on or after June 30, 2016.
  • Must be filed with the income tax return of the parent entity in which the reporting period ends and cannot be filed as a stand-alone return.
  • Can be filed for reporting periods that begin before the first required reporting period. (For more information go to Revenue Procedure 2017-23PDF)
  • Form 8975 and its schedules can be filed in the Modernized e-File (MeF) XML schema format.
  • Parent entities not permitted to file returns electronically must file Form 8975 with their paper income tax return.

International exchange of Country-by-Country Report

  • The IRS will exchange Form 8975 information automatically with tax authorities with which the United States enters into a bilateral Competent Authority Arrangement. However, a U.S. MNE group’s information will only be exchanged with those countries in which the U.S. MNE group reports doing business.
  • Exchanged information is confidential and protected pursuant to the applicable legal instrument permitting exchange.
  • Find out how to report concerns over potential disclosure or misuse of information exchanged under an international agreement.