MNE Tax have reported:
The UK's HM Revenue and Customs today announced that it will propose amendments to existing country-by-country reporting regulations applicable to large multinational enterprises to add partnerships as reporting entities.
The proposed regulation amendments, to be issued this fall, will be consistent with OECD guidance issued in June and will be applicable January 1, HMRC said.
It's important to remember that no entity has to report country-by-country reporting data unless its turnover exceeds €750 million.
And how many UK partnerships have turnover exceeding that sum? I can think of four. Let's call then PWC, Deloitte, EY and KPMG.
What are HMRC saying? Surely they are not doubting the accountancy professions brightest and best on the issue of transfer pricing, are they?
Whatever next?
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This is HMRC following the OECD, not HMRC targeting any particular business sector. See https://www.gov.uk/government/news/update-on-country-by-country-regulations
This should also include the largest law firms, including the “magic circle”, and presumably also a large number of US law firms with a UK office. Are there any other large international businesses still organised as partnerships or LLPs? Actuaries, surveyors, etc?
Depending on how the turnover is aggregated, it could also include the likes of limited partnerships holding private equity investments, and the entities through which fund managers hold their interests. I suspect this may be OECD’s real target.
Maybe