Features
Our CBCR (Country By Country Reporting) XML reporting solution leverages user-friendly Excel templates, making it easy for financial and tax professionals to input relevant data directly into familiar spreadsheets.
Our templates guide users through the data entry process, minimizing errors and streamlining reporting tasks.
We build your Country By Country Reporting using complete automatic processes and automated validation checks. We stay up-to-date with the latest specifications, ensuring that our software reflects any changes or updates. This way, your reports are always compliant with the current regulatory standards.
Optionnaly, we can do the filing to the Luxemburgish authority (ACD).
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SCALABILITY AND FLEXIBILITY
Tailor your CBCR XML reports to meet your organization’s specific needs and preferences. Our solution allows for extensive customization within the Excel templates, enabling you to adjust structures, add supplementary information, and format data according to your requirements.
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ACCURACY
Robust controls in place to prevent errors or omissions.
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TIMELINESS
Our fully automatic solution enables entities to meet the required reporting deadlines.
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USER FRIENDLY
The solution is easy for users to understand and use, with clear instructions and intuitive interfaces.
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SUPPORT
From template customization to troubleshooting assistance, our dedicated support team is here to help every step of the way. Benefit from personalized guidance and expertise as you navigate Luxembourg’s CBCR reporting requirements with confidence.
What is CbCR reporting?
CBCR, or Country-by-Country Reporting, is a requirement under the Base Erosion and Profit Shifting (BEPS) initiative developed by the Organisation for Economic Co-operation and Development (OECD). The goal of CBCR is to enhance transparency in the tax practices of multinational enterprises (MNEs).
Under CBCR, qualifying MNEs are required to provide detailed information on their global allocation of income, taxes paid, and other key indicators on a country-by-country basis. This information is intended to help tax authorities assess whether a company’s profits are in line with the economic activity and value creation in each jurisdiction where they operate.
CBCR is a tool to prevent multinational companies from shifting profits to low-tax jurisdictions and to ensure that they are paying their fair share of taxes in the countries where they conduct business. It aids tax authorities in identifying and addressing potential tax avoidance strategies and promotes a more equitable distribution of tax revenues globally.
The specific reporting requirements may vary by jurisdiction, but CBCR generally involves providing a breakdown of financial and operational data for each country in which an MNE operates. This information helps tax authorities assess transfer pricing risks, economic substance, and other factors influencing the allocation of profits within a multinational group.
What should be reported?
- Revenue and Profit:
- Total revenue generated by the MNE in each jurisdiction.
- Profit or loss before income tax.
- Income Tax Paid and Accrued:
- Total income tax paid on a cash basis.
- Total income tax accrued, which may include provisions for future tax liabilities.
- Stated Capital:
- The amount of stated capital in each jurisdiction.
- Accumulated Earnings:
- The net amount of earnings retained in each jurisdiction.
- Number of Employees:
- The total number of employees on a full-time equivalent basis in each jurisdiction.
- Tangible Assets:
- The value of tangible assets other than cash or cash equivalents in each jurisdiction.
- Nature of Business Activities:
- A brief description of the main business activities conducted in each jurisdiction.
It’s important to note that the specific requirements for CBCR may vary by jurisdiction, as each country may have its own regulations and guidelines. The OECD has developed a model template for CBCR, and many countries have adopted similar reporting standards based on the OECD’s recommendations. MNEs need to comply with the reporting requirements of each jurisdiction in which they operate to ensure transparency and compliance with international tax standards.
Does Country-by-Country Reporting (CbCR) apply to the management entity of an investment fund or to the investment fund itself?
The obligation to file CbCR could pertain to either the management companies or the investment funds, or both. Whether there’s a reporting requirement depends on which entities are mandated to consolidate their accounts under U.S. GAAP (or would be obliged if the entity were publicly traded) and are part of a Multinational Enterprise (MNE) group. For instance, an MNE group might exist if U.S. GAAP necessitates management companies to consolidate the investment fund entities (provided the MNE group meets the USD 850 million revenue threshold). MNE groups may also be present when management companies prepare separate financial statements from the investment funds. In this latter scenario, multiple MNE groups might exist, and several CbC reports might need to be filed (if each MNE group meets the USD 850 million revenue threshold and none is included in another MNE group’s CbC report).
Which countries are participating jurisdictions for CbCR?
This link provides all bilateral exchange relationships that are currently in place for the automatic exchange of CbC reports between tax authorities:
https://www.oecd.org/tax/beps/country-by-country-exchange-relationships.htm