Title 1. What is Country-by-Country (CbC) Reporting?
Description

  • CbC reporting is part of Action 13 of the Organization for Economic Cooperation and Development (OECD) Base Erosion and Profit Shifting (BEPS) Action Plan. It is intended to promote greater transparency for tax administrations by providing them with relevant and reliable information to conduct high-level transfer pricing risk assessments. To accomplish this, a competent authority will automatically exchange CbC reports prepared by multinational enterprise (MNE) groups with a reporting entity in its jurisdiction with partner jurisdiction competent authorities in all jurisdictions in which the MNE group operates, provided that a legal instrument allowing for the automatic exchange of information (e.g. Double Taxation Agreement  (DTA) or Tax Information Exchange Agreement (TIEA) is in force and a Multilateral Competent Authority Arrangement (MCAA) for the exchange of CbC reports is operative with such second-mentioned jurisdictions.


 



  • Kenya is a member of the OECD Inclusive Framework (IF) on BEPS, a group of jurisdictions committed to the implementation of the minimum standard of BEPS-related measures. Kenya introduced Sections 18B, 18C, 18D, 18E and 18F of the Income Tax Act (ITA) through the Finance Act, 2022. These sections provide for CbC reporting filing requirements which apply to returns for the years of income 2022 and subsequent years of income. It requires the ultimate parent entities and constituent entities to comply with CbC reporting obligations and, where applicable, to file a CbC Report, master file, and local file.
Category Country By Country Reporting