China (CN)

Jurisdiction Overview

419 *CBCR: Is there a local filing requirement of a global country-by-country reporting file (according to OECD’s BEPS Action 13) by large corporate groups (with a worldwide turnover higher than 750 million Euro) and local subsidiaries of foreign groups? OECD Legislation: Secondary mechanism is subject to restrictions imposed by OECD model legislation; or no secondary mechanism at all (only the domestic ultimate parent entity has to file the CbCR)
 Data Date: 2019


"With respect to the conditions under which local filing may be required (paragraph 8 (c) iv. b) of the terms of reference (OECD, 2017b), the tax administration can also request an enterprise to provide the CbC report during a special tax investigation if the MNE to which the enterprise belongs is required to prepare the CbC report in accordance with the relevant regulations of another country, and although the MNE has filed the CbC report to another country, there is no mechanism in place to exchange CbC report between China and that country. Although this condition does not reflect the details of paragraph 8 (c) iv. b) of the terms of reference (OECD, 2017b), China confirms that it will apply this provision in accordance with the wording of these terms of reference." (OECD CBCR 2018: 156). "China confirm that, as at 31 March 2019, no foreign MNEs have been required to comply with local filing rules" (OECD CBCR 2019: 130).