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BEPS Central Tracker: Summary

Reviewed and updated monthly, the BEPS Central Tracker offers a global overview of BEPS Action 13 implementation, jurisdiction by jurisdiction, which covers the introduction of country-by-country (CbC) reporting, master file and local file documentation when applicable.

CbC Report Master File Local File
Jurisdiction Effective date Revenue threshold Filling deadline Notification deadline Effective date Threshold for preparation Preparation deadline Effective date Threshold for preparation Preparation deadline
Andorra
Angola
Argentina 1-Jan-17 TBA TBA TBA
Aruba
Australia 1-Jan-16 A$1 billion Within 12 months of end of income year By the due date of the CbC report 1-Jan-16 A$1 billion Within 12 months of end of income year 1-Jan-16 A$1 billion Within 12 months of end of income year
Austria 1-Jan-16 EUR 750 million Within 12 months of end of income year By the end of the reporting fiscal year 1-Jan-16 If Turnover exceeds EUR 50 million for two consecutive fiscal years To be submitted within 30 days, only upon request, after filing of the tax return 1-Jan-16 If Turnover exceeds EUR 50 million for two consecutive fiscal years To be submitted within 30 days, only upon request, after filing of the tax return
Bangladesh
Belgium 1-Jan-16 EUR 750 million Within 12 months of end of income year By the end of the reporting fiscal year (extended to 30 September 2017 for the first year) 1-Jan-16 EUR 50 million (excluding non-recurring income) Within 12 months of end of income year 1-Jan-16 EUR 50 million (excluding non-recurring income) To be submitted with income tax return
Belize
Benin
Bermuda 1-Jan-16 EUR 750 million Within 12 months of end of income year By the end of the reporting fiscal year (extended to 1 September 2017 for the first year)
Bosnia and Herzegovina (FBiH) 1-Jan-18 BAM 1.5 billion (approx. EUR 750 million) Within 3 months of end of income year (31 March) 1-Jan-18 BAM 1.5 billion (approx. EUR 750 million) Within 45 days upon request 1-Jan-16 Related party transactions exceed BAM 500,000 Within 45 days upon request
Brazil 1-Jan-16 R$ 2.26 billion/ EUR 750 million Filing with ECF to SPED (31 July after year end) 31-Jul-17
British Virgin Islands TBA EUR 750 million
Brunei Darussalam
Bulgaria 1-Jan-16 EUR 750 million Within 12 months of end of income year 30-Sep-17
Burkina Faso
Cameroon
Canada 1-Jan-16 EUR 750 million Within 12 months of end of income year By the due date of the CbC report
Cayman Islands 1-Jan-16 EUR 750 million/ US$850 million Within 12 months of end of income year By the end of the reporting fiscal year
Chile 1-Jan-16 EUR 750 million Within six months of end of income year 30 days before filing deadline
China 1-Jan-16 RMB 5.5 billion To be filed with ultimate parent's income tax return, by 31 May 31-May-17 1-Jan-16 Either: a) the Chinese entity is part of a multinational group that files a master file; or b) related party transactions exceed RMB 1 billion To be prepared within 12 months of end of income year 1-Jan-16 Either: a) The annual amount of ownership transfer of tangible assets with related parties is over RMB 200 million; or b) The annual amount of financial asset transfers with related parties is over RMB 100 million; or c) The annual amount of ownership transfers of intangible assets with related parties is over RMB 100 million; or d) The annual amount of other related party transactions is over RMB 40 million. To be prepared by 30 June following the tax year in question. Filing within 30 days upon request
Colombia 1-Jan-16 81,000,000 TU (approximately USD 810 million) Within 12 months of end of income year TBA TBA Either: (a) gross equity on the last day of the fiscal year or period equals at least 100,000 Taxable Units (approximately US$ 1 million); or (b) gross revenues of respective year equal at least 61,000 TU (US$ 610,000); and (c) transactions are carried out with related parties TBA TBA Either: (a) gross equity on the last day of the fiscal year or period equals at least 100,000 Taxable Units (approximately US$ 1 million); or (b) gross revenues of respective year equal at least 61,000 TU (US$ 610,000); and (c) transactions are carried out with related parties TBA
The Congo, Democratic Republic of
The Congo, Republic of
Costa Rica TBA TBA TBA 1-Jan-17 TBA Within 10 days upon request 1-Jan-17 TBA Within 10 days upon request
Croatia 1-Jan-16 EUR 750 million Within 12 months of end of income year Within 4 months of end of income year
Curacao TBA TBA TBA
Cyprus 1-Jan-16 EUR 750 million Within 12 months of end of income year By the end of the reporting fiscal year; extended to 20 October 2017 in first year
Czech Republic 1-Jan-16 EUR 750 million Within 12 months of end of income year By 31 October 2017
Denmark 1-Jan-16 KR 5.6 billion Within 12 months of end of income year By the end of the reporting fiscal year 1-Jan-16 Large enterprises (SME exemption from some documentation requirements) Within 60 days upon request 1-Jan-16 Large enterprises (SME exemption from some documentation requirements) Within 60 days upon request
Egypt
Eritrea
Estonia 1-Jan-16 EUR 750 million Within 12 months of end of income year Within 6 months of end of income year 1-Jan-07 Turnover in excess of EUR 50 million; or a consolidated balance sheet of EUR43 million or more; or 250 or more employees Within 60 days upon request 1-Jan-07 Turnover in excess of EUR 50 million; or a consolidated balance sheet of EUR43 million or more; or 250 or more employees Within 60 days upon request
Finland 1-Jan-16 EUR 750 million Within 12 months of end of income year By the end of the reporting fiscal year (exceptionally extended to 31 May 2017 for fiscal years ending before that date) 1-Jan-17 Related party transactions exceed EUR 0.5 million (SME exemption from some documentation requirements) Within 60 days upon request (cannot be requested earlier than 6 months from the end of the accounting period) 1-Jan-17 Related party transactions exceed EUR 0.5 million (SME exemption from some documentation requirements) Within 60 days upon request (cannot be requested earlier than 6 months from the end of the accounting period)
France 1-Jan-16 EUR 750 million Within 12 months of end of income year By the due date of the income tax return (4 months after year end)
Gabon 1-Jan-17 FCFA 491,967,750,000 Within 12 months of end of income year By the end of the reporting fiscal year 1-Jan-17 TBA To be prepared by the time of the submission of the annual income tax return of the group’s parent entity. 1-Jan-17 TBA To be submitted at the time of the submission of the annual income tax return.
Georgia TBA TBA TBA
Germany 1-Jan-16 EUR 750 million Within 12 months of end of income year By the due date of the income tax return of the notifying entity 1-Jan-17 The German taxpayer is part of a multinational group and its revenues were EUR 100 million or greater in the prior financial year Within 60 days upon request 1-Jan-17 €5 million for intercompany goods transactions or €500,000 for other transactions Within 60 days upon request
Greece 1-Jan-16 EUR 750 million Within 12 months of end of income year TBA
Guatemala TBA TBA TBA TBA TBA TBA
Guernsey 1-Jan-16 EUR 750 million Within 12 months of end of income year Within 6 months of end of income year, for Guernsey-resident ultimate or surrogate parent companies; 30 November following the year end for other Guernsey-resident multinational group entities
Haiti
Hong Kong 1-Jan-18 EUR 750 million Within 12 months of end of income year TBA TBA Enterprises that meet two of the following criteria: annual revenue exceeding HK$100 million, assets exceeding HK$100 million and workforce exceeding 100 employees. TBA TBA Enterprises that meet two of the following criteria: annual revenue exceeding HK$100 million, assets exceeding HK$100 million and workforce exceeding 100 employees. TBA
Hungary 1-Jan-16 EUR 750 million Within 15 months of end of income year Within 12 months of end of income year
Iceland 1-Jan-17 ISK 100 billion Within 12 months of end of income year TBA
India 1-Apr-16 EUR 750 million 30 November 2017 for 2016/17 FY TBA 1-Apr-16 TBA TBA 1-Apr-16 TBA TBA
Indonesia 1-Jan-16 IDR 11 trillion Within 12 months of end of income year TBA 1-Apr-16 Either: a) gross annual revenue exceeds IDR 50 billion ($3.7 million); b) related-party transactions for tangible goods exceed IDR 20 billion in a year; c) similar transactions for services or interest payments exceed IDR 5 billion; or d) any of these transactions involve a party in a jurisdiction with a lower tax rate than Indonesia's 25% Documentation to be prepared within 4 months of the end of the income year 1-Apr-16 Either: a) gross annual revenue exceeds IDR 50 billion ($3.7 million); b) related-party transactions for tangible goods exceed IDR 20 billion in a year; c) similar transactions for services or interest payments exceed IDR 5 billion; or d) any of these transactions involve a party in a jurisdiction with a lower tax rate than Indonesia's 25% Documentation to be prepared within 4 months of the end of the income year
Ireland 1-Jan-16 EUR 750 million Within 12 months of end of income year By the end of the reporting fiscal year
Isle of Man 1-Jan-17 EUR 750 million Within 12 months and one day of end of income year Within 6 months of the end of the reporting fiscal year for resident ultimate parent entities; within one year and a day for resident entities of foreign-parented groups
Israel 1-Jan-16 NIS 3.4 billion TBA
Italy 1-Jan-16 EUR 750 million Within 12 months of end of income year TBA
Ivory Coast
Jamaica
Japan 1-Apr-16 JPY 100 billion Within 12 months of end of income year By the end of the reporting fiscal year; 31 December 2017 for foreign-parented groups 1-Apr-17 JPY100 billion In the year following the fiscal year-end of the ultimate parent company of the multinational corporation group. 1-Apr-17 Either: a) intercompany transactions more than JPY5 billion (total amount of both payment and receipt); or intangible transactions more than JPY300 million No filing requirement
Jersey 1-Jan-16 EUR 750 million Within 12 months of end of income year By the end of the reporting fiscal year (extended by concession to 31 March 2017 in the first year)
Kazakhstan
Kenya
Korea, South 1-Jan-16 KRW 1 trillion Within 12 months of end of income year Within 6 months of end of income year 1-Jan-16 KRW 100 Billion Within 12 months of end of income year 1-Jan-16 KRW 100 Billion Within 12 months of end of income year
Latvia 1-Jan-16 EUR 750 million Within 12 months of end of income year
Liberia
Liechtenstein 1-Jan-17 TBA TBA
Lithuania 1-Jan-16 EUR 750 million Within 12 months of end of income year
Luxembourg 1-Jan-16 EUR 750 million Within 12 months of end of income year By the end of the reporting fiscal year. (First notification is exceptionally postponed to 31 March 2017)
Macau
Malaysia 1-Jan-17 MYR 3 billion Within 12 months of end of income year 1-Jan-17 TBA Within 30 days upon request 1-Jan-17 TBA Within 30 days upon request
Malta 1-Jan-16 EUR 750 million Within 12 months of end of income year
Mauritius 1-Jan-18
Mexico 1-Jan-16 MXN 12 billion Within 12 months of end of income year By the end of the reporting fiscal year 1-Jan-16 MXN 644,599,005/ USD 37,368,000 Within 12 months of end of income year 1-Jan-16 MXN 644,599,005/ USD 37,368,001 Within 12 months of end of income year
Monaco
The Netherlands 1-Jan-16 EUR 750 million Within 12 months of end of income year By the end of the reporting fiscal year (extended to 1 September 2017 for the first year) 1-Jan-16 EUR 50 million Master file must be included in the taxpayer's records within the term set for submission of the corporate income tax return 1-Jan-16 EUR 50 million Local file must be included in the taxpayer's records within the term set for submission of the corporate income tax return
New Zealand 1-Jan-16 EUR 750 million Within 12 months of end of income year Not applicable: each year the Inland Revenue will contact the New Zealand-headquartered corporate groups that are required to file the CbC report
Nigeria TBA TBA TBA
Norway 1-Jan-16 NOK 6.5 billion Within 12 months of end of income year By the due date of the income tax return of the notifying entity (31 May)
Pakistan 1-Jul-16 TBA Within 30 days of a request N/A 1-Jul-16 TBA ithin 30 days upon request 1-Jul-16 TBA Within 30 days upon request
Panama 1-Jan-17 TBA TBA 1-Jan-17 TBA TBA
Papua New Guinea 1-Jan-16 2 million kina Within 12 months of end of income year By the end of the reporting fiscal year
Paraguay
Peru 1-Jan-18 Taxpayers that are members of a MNE TBA 1-Jan-17 20,000 UIT (approximately US$23.82 million) TBA 1-Jan-17 2,300 UIT (approximately US$2.74 million) TBA
Poland 1-Jan-16 EUR 750 million Within 12 months of end of income year Within 10 months of the end of the first reporting fiscal year 1-Jan-17 Revenues or expenses exceeding EUR 20 million To be prepared by tax return filing deadline. To be made available within 7 days upon request 1-Jan-17 Revenues or expenses exceeding EUR 2 million To be prepared by tax return filing deadline. To be made available within 7 days upon request
Portugal 1-Jan-16 EUR 750 million Within 12 months of end of income year By 31 May 2017
Romania 1-Jan-16 EUR 750 million Within 12 months of end of income year
Russia 1-Jan-17 RUB 50 billion Within 12 months of end of income year 8 months after the end of the reporting fiscal year 1-Jan-17 RBL 50 Billion Must be provided within 3 months of a request by the tax authority, but no earlier than 15 months after the end of the income year. 1-Jan-17 RBL 50 Billion Must be provided within 3 months of a request by the tax authority, but no earlier than 15 months after the end of the income year.
San Marino
Saudi Arabia
Senegal TBA TBA TBA TBA
Seychelles
Sierra Leone
Singapore 1-Jan-17 SGD 1.125 billion Within 12 months of end of income year N/A 1-Jan-17 Purchase of goods from all related parties S$15 million; Sale of goods to all related parties S$15 million; Loans owed to all related parties S$15 million; Loans owed by all related parties S$15 million; All other categories of related party transactions S$1 million Within 30 days upon request 1-Jan-17 Purchase of goods from all related parties S$15 million; Within 30 days upon request
Slovakia 1-Jan-16 EUR 750 million Within 12 months of end of income year By 31 March 2017 1-Jan-15 Taxpayers that are required to keep a complete documentation are: Taxpayers that are obliged to keep their accounts under IFRS; Taxpayers whom conduct transactions with related parties that are established in a non-treaty state (also where secondary adjustments are required); Taxpayers that apply for an advance tax ruling; Taxpayers that claim a deduction of losses in excess of EUR 300,000 (incurred in previous years); Taxpayers that, in the two following tax periods, claim deduction of losses in excess of EUR 400,000 incurred in previous years; Taxpayers that claim tax relief under the Research and Development Incentives Act or Investment Incentive Act Within 15 days upon request 1-Jan-15 Taxpayers that are required to keep a complete documentation are: Taxpayers that are obliged to keep their accounts under IFRS; Taxpayers whom conduct transactions with related parties that are established in a non-treaty state (also where secondary adjustments are required); Taxpayers that apply for an advance tax ruling; Taxpayers that claim a deduction of losses in excess of EUR 300,000 (incurred in previous years); Taxpayers that, in the two following tax periods, claim deduction of losses in excess of EUR 400,000 incurred in previous years; Taxpayers that claim tax relief under the Research and Development Incentives Act or Investment Incentive Act Within 15 days upon request
Slovenia 1-Jan-16 EUR 750 million Within 12 months of end of income year Within 12 months of end of income year
South Africa 1-Jan-16 R 10 billion / EUR 750 million Within 12 months of end of income year Within 12 months of end of income year
Spain 1-Jan-16 EUR 750 million Within 12 months of end of income year By the end of the reporting fiscal year 1-Jan-16 EUR 45 million To be at the disposal of Spanish Tax Administration by 26 July 2017 for fiscal year 2016 1-Jan-16 EUR 45 million To be at the disposal of Spanish Tax Administration by 26 July 2017 for fiscal year 2016
Sri Lanka
Sweden 1-Jan-16 SEK 7 billion Within 12 months of end of income year By the end of the reporting fiscal year (extended to 30 April 2017 in the first year) 1-Jan-17 250 employees and either: a) revenues of SEK 450 Million, or b) total assets of SEK 400 million To be prepared at the time of the submission of the annual income tax return of the group’s parent entity. 1-Jan-17 250 employees and either: a) revenues of SEK 450 Million, or b) total assets of SEK 400 million To be prepared at the time of the submission of the annual income tax return.
Switzerland 1-Jan-18 CHF 900 million Within 12 months of end of income year By the end of the reporting fiscal year
Turkey 1-Jan-16 TL 2,037 million Within 12 months of end of income year 1-Jan-16 TRY 250 Million End of the second month following the corporate tax declaration submission date 1-Jan-16 TRY 100 Million End of the second month following the corporate tax declaration submission date
Turks and Caicos Islands
Ukraine
UK 1-Jan-16 EUR 750 million Within 12 months of end of income year By the end of the reporting fiscal year (extended by concession to 1 September 2017 in the first year)
Uruguay 1-Jan-17 TBA TBA TBA 1-Jan-17 TBA TBA
USA 30-Jun-16 $850 million To be filed with ultimate parent's income tax return N/A
Vietnam 1-Jan-17 VND 18,000 billion To be prepared by filing date of corporate income tax return (90 days after fiscal year end). Under audit, to be submitted within 15 days upon request TBA 1-Jan-17 Annual total revenue less than VND 50 billion (US$ 2.2 million) and total related party transaction values less than VND 30 billion (US$ 1.3 million) To be prepared by filing date of corporate income tax return (90 days after fiscal year end). Under audit, to be submitted within 15 days upon request 1-Jan-17 Annual total revenue less than VND 50 billion (US$ 2.2 million) and total related party transaction values less than VND 30 billion (US$ 1.3 million) To be prepared by filing date of corporate income tax return (90 days after fiscal year end). Under audit, to be submitted within 15 days upon request

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