On April 26, 2017, New Zealand Inland Revenue (“Revenue”) published guidance on country-by-country (CbC) reporting requirements under OECD BEPS Action 13. These requirements apply to corporate groups headquartered in New Zealand with annual consolidated group revenue of over €750 million. See the required CbC Report (Form IR 1032).
Approximately 20 New Zealand-headquartered corporate groups will be affected by the CbC reporting requirements, according to Revenue. Groups with December 31 balance dates will be affected first, with data to be collected for the 12 months beginning January 1, 2016. For groups with March 31 and June 30 balance dates, data needs to be collected for the 12 months beginning April 1, 2016 and July 1, 2016 respectively.
Initial CbC reporting will occur during the 2017 calendar year. The following aggregate information will need to be collected for 2016 and subsequent years for each jurisdiction in which groups operate:
- Gross revenues (broken down by related and unrelated parties).
- Profit (loss) before income tax.
- Income tax paid (on a cash basis).
- Income tax accrued (current year).
- Stated capital.
- Accumulated earnings.
- Number of employees.
- Tangible assets other than cash and cash equivalents.
Groups will also need to list all entities resident in each jurisdiction, noting each entity’s business activities.
On June 27, 2016, New Zealand Ministers English and Woodhouse released a Cabinet paper that explains the OECD BEPS project and outlines New Zealand’s response to date, as well as planned work. The Cabinet paper says that New Zealand will issue legislation to require CbC reporting in line with the BEPS Action 13 recommendations.