Country by Country Reporting

Nov 06, 2017

Revenue has published updates to their Country by Country Reporting (CbCR) FAQs.  One of the updates tells us that the electronic filing system for submitting CbC reports to Revenue will be available on Revenue Online Service (ROS) by the end of November. 

Revenue has confirmed to us that the recent updates to the FAQs are as follows:

 Q3 has been updated to provide a link to the OECD implementation guidance on CbCR.

 Q11 and 22 have been amended to reflect a number of developments:

  1. The last paragraph of Q 11 has been removed. This is to reflect the fact that the address of each constituent entity is not mandatory on the XML schema.
  2. Q 22 has been updated to:
    1. Indicate that the ROS filing system is anticipated to go live by the end of November and taxpayers should proceed with the preparation of their XML files using the XML Schema in advance of that date. Links to both the XML Schema and the User Guide have been provided.
    2. Remind taxpayers to ensure that they have made any necessary notifications well in advance of the filing date.
  • New Q 23, 24 and 25 have been included to cover a number of XML filing issues.
  • Q27 has been updated to reflect that, Ireland will accept the OECD transitional relief for MNE groups with  short accounting periods in 2016. The OECD guidance on this issue was published in September. See question 3:  https://www.oecd.org/tax/guidance-on-the-implementation-of-country-by-country-reporting-beps-action-13.pdf. In addition the question now deals with long accounting periods.
  • Q37 has been updated to reflect the most recent number of signatories to the MCAA and regarding activated bilateral exchange relationships.
  • Q38 has been updated to confirm that equivalent CbC Reports, which contain information on constituent entities or PEs in Member States, will be exchanged with those Member States in accordance with the provisions of DAC 4.
  • A new Appendix IV has been inserted dealing with naming conventions in relation to the XML filing of CbC Reports.

The FAQs are available on the Revenue website.