Country-by-country tax reporting
Country-by-country tax reporting obligations are reshaping compliance workloads across the Financial and Capital Markets sector, driven by coordinated enforcement 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 active in over 35 jurisdictions, require financial institutions to produce granular jurisdictional profit, tax, and employee data that feeds directly into CbCR filings. Compliance teams are reconciling legal entity structures against these new disclosure requirements before local transposition deadlines hit.
Watch
- OECD Pillar Two qualified domestic minimum top-up tax filing deadlines by jurisdiction
- IRS Form 8975 enforcement priorities for U.S.-parented financial groups with foreign operations
- EU public CbCR Directive: which member states have transposed, which are late
- APAC secondary enforcement actions where CbCR data conflicts with transfer pricing filings
Recent material activity in Financial & Capital Markets
Active monitoring in place across Financial & Capital Markets. Material developments related to country-by-country tax reporting will appear here as they are published.