New Zealand has implemented Country-by-Country (CbC) reporting requirements which have been published by the OECD as part of an agreed international tax reform package addressing base erosion and profit shifting (BEPS).
Under BEPS Action 13, all large multinational enterprises (MNEs) are required to prepare a CbC report with aggregate data on the global allocation of income, profit, taxes paid and economic activity among tax jurisdictions in which they operate. CbC reports are then exchanged between tax administrations to promote greater international tax transparency.
All New Zealand-headquartered multinational groups with annual consolidated group revenue of more than NZD1.3b (equivalent to EUR750m global threshold) are required to report to Inland Revenue within 12 months of their fiscal year end.
There are approximately 27 New Zealand-headquartered multinational groups that report each year.
For CbC reporting, the following information needs to be collected and summarised for each jurisdiction in which the group operates:
- Gross revenues - broken down into related party and unrelated party categories.
- Profit (loss) before income tax.
- Income tax paid on cash basis.
- Income tax accrued - current year.
- Stated capital.
- Accumulated earnings.
- Number of employees.
- Tangible assets other than cash and cash equivalents.
In addition, details of all constituent entities resident in each jurisdiction are reported, noting the main business activity of each entity.
The information is required to be reported to Inland Revenue through myIR in the prescribed electronic format. This format is an XML file that meets the requirements of the OECD’s CbC Reporting XML schema (July 2019).
Country-by-Country Reporting XML Schema: User Guide for Tax Administrations
For more information
Further guidance on CbC reporting is available on the OECD website.
Country-by-country reporting for tax purposes | OECD
Multinational enterprises can email us questions.