Finance Bill — Schedule 19 — Multinational Enterprises — Publication of Country by Country Tax Strategy — 28 Jun 2016 at 14:30

The majority of MPs voted against requiring multinational enterprises to publish a country by country tax strategy including information on their attitude to tax planning.

MPs were considering the Finance Bill.^[1]

The amendment rejected in this vote was:

• Amendment proposed: 1, page 516, line 21, at end insert—
• ‘(2A) A group tax strategy of a qualifying group which is a MNE group must also include a country-by-country report.
• (2B) In paragraph (2A) “country-by-country report” has the meaning given by the Taxes (Base Erosion and Profit Shifting) (Country by Country Reporting) Regulations 2016.”

Had it not been rejected the above text would have been inserted into part 19 of Schedule 19 of the Bill^[2] titled Content of group tax strategy which requires UK groups to publish tax strategy containing material including:

• the attitude of the group towards tax planning (so far as affecting UK taxation)
• the level of risk in relation to UK taxation that the group is prepared to accept, and
• the approach of the group towards its dealings with HMRC

The Bill defines MNE group in reference to the "OECD Model Legislation in the OECD Country-by-Country Reporting Implementation Package as contained in the OECD’s Guidance on Transfer Pricing Documentation and Country-by-Country Reporting published in 2014". The term MNE means Multinational Enterprise.

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• [1] Parliament's webpage on the Finance Bill
• [2] Schedule 19 of the Bill as at the time of the vote

Debate in Parliament |