On 5 July 2023, the House of Commons in the United Kingdom (UK) made a significant decision by accepting Statutory Instrument No. 752/2023 to amend tax regulations on BEPS country-by-country (CbC) notification requirement. The UK government has officially released the Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) (Amendment) Regulations 2023 in the Official Gazette. The change in legislation will come into effect as of 26 July 2023.
These Regulations amend the Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting Regulations 2016 (S.I. 2016/237) (“the Principal Regulations”).
The Principal Regulations give effect to the OECD CbC Reporting Guidance set out in the “Transfer Pricing Documentation and Country-by-Country Reporting, Action 13: 2015 Final Report” published on 5th October 2015.
These Regulations amend the Principal Regulations to remove a notification requirement ancillary to the main reporting requirement imposed by the Principal Regulations and that is now considered to be unnecessary. These Regulations also make minor consequential amendments to remove redundant cross-references in the Principal Regulations to the revoked notification requirement.