USA - New regulations on Country-by-Country Reporting by MNEs

On 21 December, The US Treasury Department released a proposal on regulations that would require annual country-by-country reporting by US companies that are the ultimate parent entity of a multinational enterprise (MNE) group.

International Context

The information required to be reported on the US Country-by-Country (CbC) report was developed in coordination with other member countries of the G20 and the OECD. The OECD released final international tax recommendations on 5 October.

A spokesman for Treasury said that the department is "proud to have played a leading role in developing the BEPS recommendations to help address tax avoidance by multinational corporations."


CbC will assist in better enforcement of the federal income tax laws by providing the IRS with greater transparency regarding the operations and tax positions taken by US MNE groups.

The Treasury spokesman said that standardized CbC reporting will give tax administrations "a global picture of where profits, tax, and economic activities of multinational enterprises are reported."

Affected Companies

These proposed regulations affect US persons that are the ultimate parent entity of an MNE group that has annual revenue for the preceding annual accounting period of $850 million or more.

This document invites comments from the public on all aspects of the proposed rules and provides the opportunity for the public to request a public hearing. The comments are due 22 March, 2016.

See also our previous article: US Officials Express Concerns Regarding BEPS and CbC Reporting

Sources: US Treasury Proposed Regulations, The Hill

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