Voluntary filing: Country- by- Country Reporting (CbCR)

The rules framed under the UK use many terminologies, part of the OECD guidance. It is of utmost importance, therefore, to refer and review this guidance, while filling a CbCR.

Entities of a MNE group may choose to submit a report voluntarily on behalf of the group, subject to the condition that a member entity is resident in the United Kingdom of the said group.

It is not mandatory for the UPE, to submit a CbCR while being resident in the country.

The UPE, subject to an international concurrence, in a country of residence and part of MNE group.

HMRC has duly informed the entity, that trade measures are not operational with the country.

An entity could opt to submit a CbCR voluntarily. In such cases, it is mandatory for the eventual parent entity to inform HMRC duly documented that it has powers to do so. Notifications may be sent to HMRC through email to cbcrfiling@hmrc.gsi.gov.uk

In cases of CbCR getting submitted in the US happen to be voluntary submissions, a further notification, in this regard, to be prepared by the apex UK entity to authenticate that the CbCR report has been submitted in the US, Further, this report is to comply with”Exception B” of CbCR rules and fulfill the requirements, to locally submit a suitable report in the UK.


For ”Exception B” to be met, the apex UK entity must inform as to when the CbCR is submitted, providing the details, like name of entity, its location with respect to tax residential status, jurisdiction on its tax residence, etc.

To know more information on HMRC  ieim300000 Internal Manuals for the International exchange of information.

CbCR Example:

 MNE group, say, having their main office in the US and having calendar year as their year end, and volunteers to submit a CbCR for its reporting period of 2016, could have three distinct and different UK notification needs that are pending in 2017:

2016 CbCR filed by the group in the United States, is due by 1st September 2017.

The additional notification that the group has filed the 2016 CbCR in the United States is due by 31st December 2017.

The group, submitting 2017 CbCR in the US, with respect to its annual notification, is pending by 31st December 2017. It may be noted that the added notification is merely a obligation for the 2016 CbCR.

However, the filing is voluntary, and not needed in subsequent years. Guidance 2 was brought up by HMRC, upholding this concept and also with a view to providing additional information with respect to filing with the UK authorities.

MNE groups under CbCR and who have their main office in the United States, to verify their UK notification needs and specially, to find out if further notification is required at all.


Hope the above information is beneficial and should you need any further information in this regard or otherwise on any other related subject, please feel free to contact datatracks.com who will be more than willing to assist you!

DataTracks is a global leader in disclosure management and regulatory compliance software and services. Seven of the top 10 accounting firms and over 17,000 enterprises around the world trust our expertise that stems from 14+ years of experience. We have prepared over 200 CbC reports across UK, Ireland, Belgium, Cyprus, Singapore, Malta, Jersey, Bermuda and all regions that follow OECD standards.