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Country-by-country reporting requirements have been published by the OECD as part of an agreed international tax reform package addressing base erosion and profit shifting. These requirements apply to corporate groups headquartered in New Zealand with annual consolidated group revenue of over EUR 750 million (approximately NZ$1.3 billion).

Around 20 New Zealand-headquartered corporate groups are affected.

The following aggregate information needs to be collected for each jurisdiction in which impacted groups operate.

  • Gross revenues - broken down into related party and unrelated party categories.
  • Profit (loss) before income tax.
  • Income tax paid on cash basis.
  • Income tax accrued - current year.
  • Stated capital.
  • Accumulated earnings.
  • Number of employees.
  • Tangible assets other than cash and cash equivalents.

In addition, impacted groups need to list all their entities resident in each jurisdiction, noting also the main business activity of each entity.

Each year, we contact the New Zealand-headquartered corporate groups that are required to file the country-by-country (CbC) report and provide them with the required templates and guidance notes (including both general and specific instructions) published by the OECD.

For more information or queries about country-by-country reporting, email us at:

[email protected]

Last updated: 28 Apr 2021
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