China (People’s Republic of)
Overview of CbC reporting requirements
The People’s Republic of China (China) has implemented the BEPS Action 13 (CbC reporting) minimum standard with three recommendations for improvement.
First reporting fiscal year: Commencing on or after 1 January 2016
Consolidated group revenue threshold: RMB 5.5 billion
Filing deadline: 5 months following the end of the reporting fiscal year
The domestic legal and administrative framework
It is recommendation that China clarify the exact scope, conditions and legal basis under the minimum standard and/or the exchange of information framework for the filing exemption in relation to information relating to National Security. This recommendation remains in place since the 2017/2018 peer review.
It is recommended that China amend its legislation or otherwise takes steps to ensure that local filing is only required in the circumstances contained in the terms of reference. This recommendation remains in place since the 2017/2018 peer review.
The exchange of information framework
China’s 2017/2018 peer review included a recommendation that China should continue to work actively towards putting in place qualifying competent authority arrangements with jurisdictions of the Inclusive Framework that meet the confidentiality, consistency and appropriate use conditions and with which China has an international exchange of information agreement in effect that allows for the automatic exchange of tax information. China has since notified under the MCAA for CbC reporting to activate relationships with all jurisdictions which meet the requirements and this recommendation is therefore removed.
It is recommended that China implement a process to ensure that each of the mandatory fields of information required in the CbC reporting template are present in the information exchanged. This recommendation remains in place since the 2018/2019 peer review.