Country-by-country tax reporting
Country-by-country tax reporting obligations are tightening around technology and AI companies, driven by coordinated pressure from the Organisation for Economic Co-operation and Development's Inclusive Framework, the U.S. Internal Revenue Service, and the European Commission's Directorate-General for Taxation and Customs Union. The OECD's Pillar Two global minimum tax rules, now being transposed into domestic legislation across APAC and EU member states, are forcing tech firms to reclassify IP holding structures and reallocate profits in ways that trigger new CbCR filings. Compliance teams are currently reconciling entity-level data across jurisdictions before local implementation deadlines hit.
Watch
- OECD Pillar Two local transposition deadlines vary by jurisdiction: track each separately
- IRS Schedule UTP disclosure requirements expanding scrutiny of tech IP transfer pricing
- EU Public CbCR Directive: mandatory disclosure for in-scope multinationals from fiscal year 2025
- Qualified Domestic Minimum Top-up Tax elections now available in several APAC jurisdictions
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