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Article 13.1 of the Corporate Income Tax Regulations (Spain)
Article 13.1 of the Corporate Income Tax Regulations (Reglamento del Impuesto sobre Sociedades, RIS), approved by Royal Decree 634/2015, regulates information and documentation on related entities and transactions. This article establishes that entities resident in Spain that qualify as the parent of a group, as defined in Article 18.2 of the Corporate Income Tax Law (LIS),…
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Country by Country Regulatory Framework in Spain
Country by Country (CbC) reporting is a tax transparency requirement for large multinational groups, which must disclose financial and tax information broken down by jurisdiction. In Spain, the regulatory framework has been adapted to both OECD guidelines (BEPS Action 13) and European regulations, with some specific national features. 1. Reporting Obligation: Form 231 2. Transposition of…
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Country-by-Country Reporting (CbCR) in Spain
Spain has incorporated Country-by-Country Reporting (CbCR) requirements into its domestic tax legislation, in line with OECD/G20 BEPS Action 13. These rules aim to enhance transparency for tax administrations and ensure that profits are taxed where economic activities take place. This guide outlines the main aspects of CbCR regulation in Spain, including who is subject to…
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Country-by-Country Reporting (CbCR) in Brazil
Brazil has adopted Country-by-Country Reporting (CbCR) as part of its commitment to the OECD/G20 Base Erosion and Profit Shifting (BEPS) Action 13 framework. The requirements apply to certain multinational enterprise (MNE) groups operating in Brazil and are governed by specific Brazilian tax regulations. This guide outlines Brazil’s CbCR obligations, including the regulatory framework, filing procedures,…
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Country-by-Country Reporting (CbCR) in the Cayman Islands
The Cayman Islands have implemented legislation requiring Country-by-Country Reporting (CbCR) in line with the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13. As a significant international financial centre, the Cayman Islands are committed to global tax transparency and have adopted regulations that apply to certain multinational enterprise (MNE) groups. This guide outlines the CbCR…
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Country-by-Country Reporting (CbCR) in Montserrat
As of the latest available information, Montserrat has not introduced formal legislation requiring Country-by-Country Reporting (CbCR) in accordance with the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13. However, multinational enterprise (MNE) groups with operations in Montserrat may still be impacted indirectly through CbCR obligations in other jurisdictions. This guide provides an overview of…
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Article 76-A of the Mexican Income Tax Law in Mexico
Article 76-A of the Mexican Income Tax Law (Ley del Impuesto sobre la Renta, LISR) outlines specific obligations for taxpayers involved in transactions with related parties. These obligations focus on filing annual informative declarations to ensure compliance with transfer pricing rules and transparency in multinational operations. Below are the key details: Obligations Under Article 76-A Taxpayers…
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Country-by-Country Reporting (CbCR) in Mexico
Mexico has been a proactive adopter of the OECD’s Base Erosion and Profit Shifting (BEPS) framework, including the implementation of Country-by-Country Reporting (CbCR) as part of Action 13. Since 2016, multinational enterprise (MNE) groups operating in Mexico have been required to comply with specific transfer pricing documentation obligations, including CbCR, to improve tax transparency and…
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Leverage AI tools and resources for your business
Artificial Intelligence (AI) is the ability of a computer program or machine to mimic human-like behavior. For example, to mimic visual senses, speech recognition, decision-making, natural language understanding, and so on. It’s not a technology of itself, but rather a goal set by technologists to imitate human intelligence. Generative AI is a subset of AI. AI can…
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Country-by-Country Reporting (CbCR) in Palestine
Palestine has not formally adopted Country-by-Country Reporting (CbCR) regulations aligned with the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13 framework. This absence, however, cannot be viewed in isolation from the broader political context: the ongoing Israeli occupation has imposed severe structural limitations on Palestine’s institutional and economic development. The entrenched system of Zionist…
CbC Reporting
Country-by-Country Reporting requirements, solutions, FAQs and general info.
CbC Reporting 