Filing of CbC reports | International Taxation: OECD/G20 BEPS Action

Obligation to file a country-by-country report

The legal obligation to file a country-by-country report (cbcr) arises under the two following circumstances:

The Hong Kong entity itself is the ultimate parent entity (the UPE) of a reportable group; or
A non-UPE Hong Kong entity of a reportable group satisfies the condition for filing the CbC reports specified under section 58I(1), subject to the exception provided under section 58I(2).

See the legal texts of section 58E and section 58F:

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Our Company has been in business since 1993. The areas of our China operations expand gradually from tax to corporate service in the PRC, and from the Pearl River Delta in Southern part of China to the North, including Beijing and Shanghai.
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