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New queries, issue 4667

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09 October 2018

Issue: 4667 / Categories: Forum & Feedback

On report; Retirement fund; Back of the grid; No show

On report

CbC filing requirement for UK subsidiary of non-UK MNE.

Does a company that is a standalone UK subsidiary of a non-UK headed parent multinational enterprise group need to file a country-by-country (CbC) report under the new Finance Act 2016 rules?

According to my reading of the CbC reporting requirements in HMRC’s manual on international exchange of information a UK subsidiary of a foreign-headed multinational enterprise group that has no subsidiaries of its own and is not a top UK entity preparing consolidated financial statements does not fall within the definition of a ‘UKE’. It is therefore outside the scope for filing a CbC report.

I should be interested to know Taxation readers’ views and comments on this.

Query 19 255– Susan.

Retirement fund

Separating business and properties into two companies.

Our clients a husband and wife jointly own a limited...

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New queries, issue 4667

© Copyright LexisNexis 2024. All rights reserved.

09 October 2018

On report; Retirement fund; Back of the grid; No show

On report

CbC filing requirement for UK subsidiary of non-UK MNE.

Does a company that is a standalone UK subsidiary of a non-UK headed parent multinational enterprise group need to file a country-by-country (CbC) report under the new Finance Act 2016 rules?

According to my reading of the CbC reporting requirements in HMRC’s manual on international exchange of information a UK subsidiary of a foreign-headed multinational enterprise group that has no subsidiaries of its own and is not a top UK entity preparing consolidated financial statements does not fall within the definition of a ‘UKE’. It is therefore outside the scope for filing a CbC report.

I should be interested to know Taxation readers’ views and comments on this.

Query 19 255– Susan.

Retirement fund

Separating business and properties into two companies.

Our clients a husband and wife jointly own a limited...

If you or your firm subscribes to Taxation.co.uk, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Subscribe Now...

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.

Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.

Issue:

4667

Categories: Forum & Feedback [1]

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