The UK and USA governments have agreed to exchange tax information from multinational enterprises in country by country reports (CBCR).
The reports from companies with at least $850m in revenue filed with the USA’s Internal Revenue Service (IRS) will be exchanged with the UK’s Her Majesty’s Revenue and Customs (HMRC), and vice versa for UK multinational groups with at least €750m (USD $902.3m). This is under the condition that the multinational is a resident for tax purposes or has a permanent establishment in the UK or USA.
The entity reports aggregate profit or loss before income tax, income tax paid, capital for each constituent entity, accumulated earnings, total full time employees and net value of tangible assets. They must file for each tax jurisdiction where at least one constituent entity resides.
Other countries that have CBCR exchange agreements with the USA include; Australia, Belgium, Brazil, Canada, Denmark, Estonia, Guernsey, Iceland, Ireland, the Isle of Man, Jamaica, Latvia, Malta, the Netherlands, New Zealand, Norway, Slovakia, South Africa, and South Korea.