Tax Administration Act, 2011 (Act No. 28 of 2011)

Regulations

Regulations for purposes of Paragraph (b) of the Definition of "International Tax Standard" in Section 1 of the Tax Administration of the Tax Administration Act, 2011 (Act No. 28 of 2011), promulgated under Section 257 of the Act, Specifying the Country-By-Country Reporting Standard for Multinational Enterprises

Article 4 : Country-by-Country Report
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1. For purposes of these Regulations, a Country-by-Country Report with respect to an MNE Group is a report containing:
(i)Aggregate information relating to the amount of revenue, profit (loss) before income tax, income tax paid, income tax accrued, stated capital, accumulated earnings, number of employees, and tangible assets other than cash or cash equivalents with regard to each jurisdiction in which the MNE Group operates;
(ii)An identification of each Constituent Entity of the MNE Group setting out the jurisdiction of tax residence of such Constituent Entity, and where different from such jurisdiction of tax residence, the jurisdiction under the laws of which such Constituent Entity is organised, and the nature of the main business activity or activities of such Constituent Entity.

 

2.The Country-by-Country Report must contain the information set out in, and apply the definitions and instructions contained in, the standard template set out in "Annex III to Chapter V" set out in the OECD/G20 Base Erosion and Profit Shifting Project Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 – 2015 Final Report.