Country-by-Country Reporting (CbCR) Compliance: Prepare for the 31st December 2024 Deadline

How can we assist you?

We have assembled an experienced team of professionals to support you with CbCR notification(s) and filing process. Our experience encompasses several levels of assistance. Depending on your needs and your characteristics, our dedicated team saves you time and helps to manage your tax and transfer pricing risks with our distinctive technology.

1. CbCR scope 

• Assessment of the CbCR obligations pertaining to your MNE Group; 
• In-depth review of the MNE Group's consolidation requirements in light of the applicable CbCR rules. 

2. CbCR technical guidance

• Preparation of a written guidance informing on the information to be collected for the CbCR filing based on latest releases from OECD as well as insights / interpretations from our experienced team of CbCR professionals. Our guidance also include the latest CbCR updates in relation to the EU Pillar Two initiative.

3. CbCR compliance obligations in Luxembourg 

•  Support in the review of the CbCR and filing in Luxembourg; 
•  Support in the preparation of the CbCR notification(s) and filing in Luxembourg.

4. Pillar Two qualified CbCR

• On 22 December 2023, Luxembourg enacted the law transposing the EU Pillar Two Directive. The law includes the Transitional Safe Harbour Rules that were issued by the OECD in December 2022 including the terms of a Transitional CbCR Safe Harbour. The aim is to mitigate the undertaking of detailed GloBE calculations in respect of a jurisdiction and potentially be exempt from any top-up taxes based on its qualifying CbCR and financial accounting data. 
• Our CbCR team can assist you with various services as part of achieving a qualified CbCR so to benefit from up to three years of a Pillar Two exemption (subject to effectively meeting one of the transitional safe harbours). 

5. Transfer Pricing and CbCR Risk Assessment

• Multi-level risk assessment (i.e. it can be an audit ready document), using the information included in the CbC Report(s) as a basis:
  • Risk Assessment (basic features) - Our PwC tool, CbCR Analyzer, (i) identifies potential data inaccuracies when preparing the CbCR and (ii) identifies the potential TP or tax exposures coming from the information included in the CbCR; 
  • Advanced Risk Assessment (full pack) - We perform an advanced risk assessment for additional checks such as: (i) year-on-year assessments; and (ii) peer-group comparison. In addition, our transfer pricing CbCR expertise combined with internally developed IT solutions can help you to visualize, understand, anticipate, and better manage TP risks connected to the CbCR filing.