Country-by-country tax reporting
Country-by-country tax reporting obligations are landing hard on Energy, Power & Commodities firms, driven by the Organisation for Economic Co-operation and Development's Pillar Two framework and its domestic transpositions now active across EU member states and APAC jurisdictions. The U.S. Internal Revenue Service and Her Majesty's Revenue and Customs have both issued updated CbCR filing guidance that intersects directly with the complex cross-border entity structures common in commodity trading, upstream extraction, and power generation. Compliance teams are currently reconciling constituent entity definitions against intercompany pricing arrangements before annual filing windows close.
Watch
- OECD Pillar Two GloBE Rules: domestic minimum top-up tax applicability to upstream JV structures
- IRS Form 8975 filing thresholds for consolidated groups with commodity trading subsidiaries
- EU public CbCR Directive enforcement deadlines for fiscal years beginning on or after January 2025
- HMRC's updated transfer pricing and CbCR compliance guidelines issued December 2023
- Qualified Domestic Minimum Top-up Tax elections in Australia affecting LNG and mining entities
Recent material activity in Energy, Power & Commodities
Active monitoring in place across Energy, Power & Commodities. Material developments related to country-by-country tax reporting will appear here as they are published.