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Brazil Consults On CbC Reporting Requirement

by Mike Godfrey, Tax-News.com, Washington

10 November 2016


On November 7, 2016, Brazil's Finance Ministry released for public comments a draft Normative Instruction to formally introduce a new country-by-country (CbC) reporting requirement for large corporations.

The draft Instruction, released in Portuguese, would introduce reporting requirements on Brazilian ultimate parent entities with annual consolidated group revenues of over BRL2.260 trillion for Brazilian tax residents, or otherwise EUR750m (USD816m) or the local equivalent. They would be required to file CbC reports annually with the tax authority, documenting their revenue, profit, taxes paid, and accrued, number of employees, capital, retained earnings, and tangible assets for each tax jurisdiction in which they do business.

The new CbC reporting requirement will apply to financial periods beginning from 2016. Penalties would apply if a MNE fails to provide a required CbC report on time.

The CbC report is one element of a new three-tiered standardized approach to transfer pricing documentation as proposed by the OECD in base erosion and profit shifting (BEPS) Action 13.

The consultation will be open until November 21.

TAGS: compliance | Finance | tax | business | tax compliance | tax avoidance | law | employees | ministry of finance | multinationals | legislation | tax planning | transfer pricing | Brazil | tax reform | BEPS

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