Country-by-Country reporting: What are the rules and who is impacted?

A Country-by-Country (CbC) report summarises the taxes, profits and activities of a multinational group (MNG) in each jurisdiction in which they operate. HMRC uses this information to identify potential tax risks and shares it with other global tax authorities so they can assess too.

When must a Country‑by‑Country report be filed?

A CbC report must be filed within 12 months of the end of the relevant financial year in which the MNG meets the reporting requirement. Penalties may be charged to the MNG if they fail to file a report by the filing deadline or provide an inaccurate report.

Who must file a Country-by-Country report?

A CbC report must be sent to HMRC if an MNG has:

1. Entities in the UK and at least one other country; and
2. Annual consolidated revenue of €750 million for the financial year before the reporting period.

While the ultimate parent entity (UPE) has responsibility for sending a report, a UK entity may need to submit a CbC report if their UPE doesn’t need to in:

• The UK; or
• A country which collects CbC reports and exchanges them with the UK.

Registration and submission requirements

Before sending the report, if the MNG doesn’t have a CBC ID, they must register online to give notice to HMRC that they will be filing a CbC report.

The CbC report must be submitted as an XML document because they can be validated and provide a common medium for exchange between the countries who have introduced CbC reporting rules.

Once the CbC report is submitted, HMRC will check for mistakes or incomplete information and may request corrections to be made to make sure the report is accurate.

What penalties apply for non-compliance?

Penalties can apply if you fail to meet your obligations, including:

• Missing filing deadlines
• Failing to notify HMRC
• Not providing requested information
• Submitting inaccurate data

Potential penalties include:

• £300 initial fine per failure
• £60 per day for ongoing non-compliance
• Up to £3,000 per report for inaccuracies

HMRC may also request corrections or further explanations where issues are identified.

We’re here to help

CbC reporting requirements can be complex, particularly for groups operating across multiple jurisdictions. If your business is approaching the thresholds for submitting a country-by-country report, or if you’re unsure whether you need to submit a CbC report, our specialist Corporate Tax team can help. Get in touch for support.