Taxes (Country-By-Country Reporting) Regulations 2015.
Statutory Instruments
Source: Statutory Instruments

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paragraphs: These Regulations may be cited as the Taxes (Country-By-Country Reporting) Regulations 2015.
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paragraphs: These Regulations shall come into operation on 1 January 2016.
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paragraphs: In these Regulations—
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paragraphs: (1) Subject to Regulation 5, a domestic constituent entity of an MNE group shall provide to the Commissioners an equivalent country-by-country report with respect to a fiscal year, where—
(a) the ultimate parent entity of that MNE group is not required to provide a country-by-country report in its jurisdiction of tax residence,
(b) the jurisdiction in which the ultimate parent entity of that MNE group is resident for tax purposes does not have in effect, by the latest date specified in Regulation 8, a qualifying competent authority agreement with the State that provides for the exchange of country-by-country reports, or
(c) there has been a systemic failure by the jurisdiction of tax residence of the ultimate parent entity of that MNE group and the Commissioners have notified the domestic constituent entity that such a failure has occurred.
(2) The notification referred to in paragraph (1)(c) may be made by the Commissioners in such form and manner, including by electronic means, as may be specified by the Commissioners from time to time.
(3) Where paragraph (1) applies and there is more than one domestic constituent entity of the same MNE group—
(a) the MNE group may designate one of its domestic constituent entities to provide the equivalent country-by-country report, and
(b) the domestic constituent entity designated under subparagraph (a) shall notify the Commissioners, not later than the latest date specified in Regulation 8, that it has been so designated.
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paragraphs: (1) Regulation 4 shall not apply where a MNE group appoints a surrogate parent entity and the following applies:
(a) one or more of the circumstances set out in Regulation 4(1) apply;
(b) the jurisdiction in which the surrogate parent entity is resident for tax purposes—
(i) requires the filing of country-by-country reports,
(ii) has in effect, by the latest date specified in Regulation 8, a qualifying competent authority agreement with the State that provides for the exchange of country-by-country reports,
(iii) has not notified the Commissioners of an event mentioned in Regulation 4(1)(c), and
(iv) has been notified of the identity of the surrogate parent entity;
(c) a notification has been provided to the Commissioners in accordance with Regulation 6(2).
(2) A surrogate parent entity resident in the State for tax purposes shall provide a country-by-country report to the Commissioners in accordance with Regulation 8.
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paragraphs: (1) An ultimate parent entity resident in the State for tax purposes or a surrogate parent entity resident in the State for tax purposes shall, not later than the last day of the fiscal year to which a country-by-country report relates, notify the Commissioners in writing that it is such an entity.
(2) Subject to paragraph (3), a domestic constituent entity shall, not later than the last day of the fiscal year to which a country-by-country report relates, notify the Commissioners in writing of the identity and jurisdiction of tax residence of the reporting entity.
(3) Where there is more than one domestic constituent entity of the same MNE group, that MNE group may nominate one such domestic constituent entity for the purposes of paragraph (2).
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paragraphs: Information required to be provided or notifications required to be made to the Commissioners under the principal section or these Regulations shall be delivered in such form and manner, including by electronic means, as may be specified by the Commissioners from time to time and to such office of the Commissioners as is so specified.
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paragraphs: Country-by-country reports and equivalent country-by-country reports required to be provided under these Regulations shall be provided to the Commissioners not later than 12 months after the last day of the fiscal year to which the country-by-country report relates, being a fiscal year commencing on or after 1 January 2016.
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paragraphs: Subsections (7) and (8) of the principal section shall be construed for the purposes of these Regulations, as if the references to a country-by-country report in those subsections included a reference to an equivalent country-by-country report.
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paragraphs: The Commissioners may nominate, in writing, any of their officers to perform any acts and discharge any functions authorised by these Regulations to be performed or discharged by them.