Country-by-Country (CBC) Report Filing Services | BEPS Compliance Hong Kong

Country-by-Country (CBC) Report Services

The Country-by-Country (CBC) Report is a key filing requirement under BEPS Action 13 of the OECD/G20 Inclusive Framework. It requires multinational enterprise (MNE) groups with consolidated revenue of EUR 750 million or more to report annually on the allocation of income, profit, taxes paid, and economic activity across each jurisdiction in which they operate.

Hong Kong implemented CBC reporting requirements under the Inland Revenue Ordinance (Cap. 112) effective from 1 January 2018. MNE groups with Hong Kong constituent entities must file their CBC Report within 12 months after the end of the reporting financial year.

At Deep Blue CPA Limited, our team of AFRC registered CPAs provides end-to-end CBC Report compliance services — from threshold assessment and notification filing to full CBC Report preparation and IRD correspondence. We help MNE groups navigate the complexities of BEPS Action 13 with confidence and precision.

Our CBC Report Services

CBC Report Preparation & Filing

• Threshold assessment — determining whether your MNE group meets the EUR 750 million consolidated revenue threshold for CBC reporting obligations
• Data collection coordination — working with group entities across jurisdictions to gather revenue, profit, tax paid, stated capital, accumulated earnings, employee count, and tangible asset data
• Table 1 preparation — completing the jurisdiction-by-jurisdiction allocation template in the prescribed XML schema or PDF format
• Electroni c filing — submission of the CBC Report to the IRD through the Hong Kong government's designated electronic filing system
• Deadline management — ensuring filing within 12 months of the reporting financial year end to avoid penalties

CBC Notification Filing

Under Hong Kong's CBC reporting framework, constituent entities of an MNE group must designate a reporting entity and file a CBC notification with the IRD. We handle:

• Notification preparation — completing the CBC notification form identifying the reporting entity and filing method
• Surrogate parent entity designation — assisting with documentation where a non-HK entity is appointed to file on behalf of the group
• Timely submission — ensuring notification is filed before the CBC Report deadline
• Multi-entity coordination — managing notification filings for all Hong Kong constituent entities within the group

Surrogate Parent Entity Arrangements

Where the ultimate parent entity of an MNE group is not tax-resident in Hong Kong, a surrogate parent entity may be appointed to file the CBC Report on behalf of the group. We provide:

• Surrogate eligibility assessment — evaluating whether the surrogate parent entity's jurisdiction has a qualifying competent authority agreement for automatic exchange with Hong Kong
• Surrogate parent entity documentation — preparing supporting documentation for the surrogate parent entity arrangement
• Cross-jurisdiction coordination — liaising with tax advisors in other jurisdictions to ensure compliance with both local and Hong Kong requirements
• Notification for surrogate arrangements — ensuring the Hong Kong notification properly reflects the surrogate parent entity arrangement

CBC Compliance Review

• Existing filing review — reviewing previously filed CBC Reports for accuracy and completeness
• Data consistency checks — verifying alignment between the CBC Report, master file, local file, and transfer pricing documentation
• Gap analysis — identifying missing data points or inconsistencies across jurisdictions
• Amended filing support — preparing and filing amended CBC Reports where errors or omissions are identified

CBC Report Filing Requirements in Hong Kong

Why Choose Deep Blue CPA for Your CBC Report Needs?

• AFRC Registered CPA Firm (Registration No. M0307) — all CBC services are supervised by qualified certified public accountants with practising certificates
• BEPS Action 13 Specialists — deep expertise in OECD CBC reporting standards, Hong Kong implementing legislation, and cross-border filing obligations
• MNE Group Experience — extensive experience serving multinational groups across diverse industries with complex global structures
• End-to-End Compliance — from threshold assessment and notification filing to CBC Report preparation and IRD correspondence, we cover the full compliance cycle
• Penalty Risk Mitigation — proactive deadline management and data quality assurance to minimise the risk of penalties for non-compliance or inaccurate filing

Frequently Asked Questions

What is a Country-by-Country (CBC) Report?

A Country-by-Country (CBC) Report is a filing requirement under BEPS Action 13 of the OECD/G20 Inclusive Framework. The report provides tax authorities with a standardised template showing the allocation of revenue, profit, income tax paid, and employees across each jurisdiction in which a multinational enterprise (MNE) group operates. The CBC Report comprises three parts: a master file (global business overview), a local file (detailed related-party transactions), and the country-by-country report itself (jurisdictional allocation data).

Which groups must file a CBC Report in Hong Kong?

MNE groups with consolidated group revenue of at least EUR 750 million (approximately HK$6.8 billion) in the immediately preceding financial year must file a CBC Report in Hong Kong. The Hong Kong Inland Revenue Department (IRD) implemented the CBC reporting framework under the Inland Revenue Ordinance (Cap. 112) with effect from 1 January 2018. If the ultimate parent entity is tax-resident in Hong Kong, the group must file through the Hong Kong entity.

What is the CBC notification requirement in Hong Kong?

Hong Kong constituent entities of an MNE group that are required to file a CBC Report must designate one of the constituent entities as the reporting entity. The reporting entity must file a CBC notification with the IRD before the CBC Report filing deadline. The notification identifies which entity will file the CBC Report and whether a surrogate parent entity arrangement is being used. Even if a surrogate parent entity is filing on behalf of the group, the notification must still be submitted.

When is the CBC Report due in Hong Kong?

The CBC Report must be filed within 12 months after the end of the reporting financial year of the MNE group. For example, for an MNE group with a financial year ending 31 December 2025, the CBC Report is due by 31 December 2026. The CBC notification must be filed before the CBC Report deadline, typically at least 3 months before the reporting deadline.

What is a surrogate parent entity?

A surrogate parent entity is a constituent entity of the MNE group that is tax-resident in a jurisdiction other than the ultimate parent entity's jurisdiction. This entity is appointed by the group to file the CBC Report on behalf of the entire MNE group. The surrogate parent entity arrangement is used where the jurisdiction of the ultimate parent entity does not require CBC reporting or does not have a qualifying competent authority agreement for automatic exchange with Hong Kong.

What penalties apply for non-compliance?

Non-compliance with Hong Kong's CBC reporting requirements can result in significant penalties under the Inland Revenue Ordinance. The maximum penalty is a Level 5 fine of HK$50,000 plus an additional penalty of three times the amount of tax undercharged. Specific offences include failure to file the CBC Report, failure to file the notification, filing inaccurate or misleading information, and failure to maintain adequate records. Different penalty levels apply depending on the nature of the offence, with daily default penalties for continuing non-compliance.

Related Services

• Transfer Pricing Services — TP documentation and advisory for related party transactions
• Hong Kong Profits Tax — Tax return filing and compliance for Hong Kong companies
• Hong Kong Salaries Tax — Employment income tax compliance for employers and employees
• Tax Audit & Tax Investigation — IRD enquiry handling and dispute resolution
• Bookkeeping Services — Accurate financial records to support timely tax filing