Tax English: CbCR - English For Cool Dudes

📚 Key Vocabulary

Click on each term to reveal its definition.

Country-by-Country Report (CbCR)

An annual report for multinational enterprises (MNEs) detailing global allocation of income, taxes paid, and other economic activity on a country-by-country basis. MNEs with consolidated revenues over **€750 million** are generally required to file CbCR.

Master File

A standardized document providing a high-level overview of a multinational group's business, including its organizational structure and transfer pricing policies.

Local File

A detailed document providing specific information on local intercompany transactions, prepared for each country where a multinational group operates.

Ultimate Parent Entity (UPE)

The entity at the top of a multinational group's ownership structure that is not controlled by any other entity. It is typically the entity responsible for filing the CbCR.

Surrogate Parent Entity

A substitute entity designated by a multinational group to file the CbCR in certain circumstances, such as when the UPE is not required to file.

❓ Quiz: CbCR Fundamentals

1. What is the primary purpose of the Country-by-Country Report?

2. What is the typical consolidated group revenue threshold for CbCR filing?

3. Which entity is generally responsible for filing the CbCR?

🔗 Match the Term to its Definition

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Definition

📝 Scenario: Fill in the Blanks

Click a word from the bank and then click a gap. **To deselect, click the filled gap to return the word.**

1. The CbCR data allows tax authorities to conduct a high-level ... before launching a full audit.

2. The report promotes global tax ... by exposing where MNE profits are booked.

3. Data is presented on a per-country basis, meaning each ... is analyzed separately.

4. The primary concern is ensuring that profit aligns with genuine ....