Change of Country-by-Country Reporting Scheme in the UK

Change of Country-by-Country Reporting Scheme in the UK

Country-by-Country Reporting Schema updated to XML 2.0 for submissions to HMRC in the UK.

Sarah Norton

Director, B2B Tax Ps and As

KPMG in the UK


The OECD published a new version of the XML Schema (version 2.0) for Country-by-Country (CbC) Reporting in June 2019 and all CbC reports submitted to HMRC on or after 1 January 2021 must use the new 2.0 XML format.

Broadly, the CbC reporting regime is part of the OECD's Base Erosion and Profit Shifting (BEPS) Action 13 and applies to multinational enterprise (MNE) groups with combined revenue of €750 million or more.

The change impacts all large MNE groups which are required to submit a CbC report under the UK's CbC reporting regime.

There is no change to the key financial data required in Table 1 of the CbC report and the changes to version 2.0 are minor admin changes. The key changes for UK CbC tax filings are:

  • The Reporting Period Start field is mandatory to complete;
  • The Reporting Role needs to be specified and accepted values are:
    • Ultimate Parent Entity;
    • Surrogate Parent Entity;
    • Local Filing in the framework of an international exchange; and
    • Local Filing with Incomplete Information.
  • There is a new field in Table 2, i.e. Ultimate Parent Entity Role. This is an optional field designed so that the Reporting Entity can be identified amongst the constituent entities. Accepted values are:
    • Ultimate Parent Entity;
    • Reporting Entity; and
    • Both (Ultimate Parent Entity and Reporting Entity).
  • An address for every Constituent Entity in Table 2 is required – including the City at a minimum.

KPMG has updated its software to reflect the above changes and to comply with HMRC and OECD requirements. We are pleased to assist our clients with the conversion of their CbC data to the appropriate format to submit to HMRC.

If you would like to hear more about how CbC reporting may affect your business and what you can do about it, please speak to your usual contact or Sarah Norton and Judith Gibbs.

For further information please contact :

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