The main change of CbCR requirements that will impact the reporting and compliance burden on U.K. companies relates to the additional notification requirement. This change is in line with the OECD Model and the EU Directive on Administrative Cooperation (2011/16/ EU, or DAC4) on mandatory exchange of information. It will possibly not be welcomed by companies as it creates an additional deadline outside the annual selfassessment return process, even though the actual notification will probably be identical for later years for most companies.

Alvarez & Marsal can conduct a high-level analysis of your company’s financial and functional profile in order to help you identify any areas of concern with regards to global documentation requirements under BEPS Action Plan 13 and transfer pricing generally.

Time is fast approaching for many MNEs to submit their CbCR with the revenue authorities. Before doing so, it is essential that you and other members of the senior management team fully understand the implications of how your data may be interpreted by the authorities.

This edition of Tax Advisor Weekly discusses some practical aspects related to the introduction of country-by-country (CbC) reporting by the Internal Revenue Service and the audit risks large and mid-sized companies may face following the submission of their CbC reports.