What metrics are reported in a CbC Report?

For each jurisdiction: revenue (third-party and intragroup), pre-tax profit/loss, income tax paid, income tax accrued, stated capital, accumulated earnings, number of employees, and tangible assets. The report is filed in the parent jurisdiction and shared with treaty partners via automatic exchange of information.

How are CbC Reports used by tax authorities?

Tax authorities use CbC Reports as a risk assessment tool, not for direct tax assessment. Significant profit allocation to low-tax jurisdictions with few employees or assets flags potential profit shifting for audit selection. Mismatches between where functions are performed (employees, assets) and where profits are reported are red flags.

BEPS Country-by-Country Reporting Threshold

Determine whether a multinational enterprise must file CbC Report based on group revenue threshold (EUR 750 million consolidated), and calculate key metrics required: revenue, profit, tax paid, employees per jurisdiction.

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Frequently Asked Questions

What metrics are reported in a CbC Report?

How are CbC Reports used by tax authorities?