Bentuk 8975 Instruksi termasuk Jadwalkan A
Instruksi untuk Form 8975 dan Jadwal A (Form 8975), Laporan Negara-by-Negara
Rev. Oktober 2020
Formulir Terkait
- Bentuk 8975 Jadwal A - Fikih Pajak dan Informasi Entitas Konsituen
- Bentuk 8975 - Sitemap
Department of the Treasury
Internal Revenue Service
Instructions for Form 8975
and Schedule A (Form 8975)
(Rev. December 2020)
Country-by-Country Report
Section references are to the Internal Revenue Code unless
otherwise noted.
Additionally, the term “business entity” includes any entity
with a single owner that may be disregarded as an entity
separate from its owner under Regulations section
301.7701-3, and any permanent establishment (described
below) that prepares financial statements separate from
those of its owner for financial or tax reporting, regulatory, or
internal management control purposes.
Future Developments
For the latest information about developments related to
Form 8975, Schedule A (Form 8975), and their instructions,
such as legislation enacted after they were published, go to
A decedent's estate or a bankruptcy estate described in
section 1398 is not a business entity.
General Instructions
Constituent entity. With respect to a U.S. MNE group, a
constituent entity is any separate business entity of such U.S.
MNE group but does not include a foreign corporation or
foreign partnership for which information is not otherwise
required to be furnished under section 6038(a) (determined
without regard to Regulations sections 1.6038-2(j) and
1.6038-3(c)) or any permanent establishment of such foreign
corporation or foreign partnership.
Purpose of Form
Certain U.S. persons that are the ultimate parent entity of a
U.S. multinational enterprise (U.S. MNE) group with annual
revenue for the preceding reporting period of $850 million or
more are required to file Form 8975.
Form 8975 and Schedules A (Form 8975) are used by
certain information with respect to the filer’s U.S. MNE group
on a country-by-country basis. The filer must list the U.S.
MNE group’s constituent entities, indicating each entity’s tax
jurisdiction (if any), country of organization and main
business activity, and provide financial and employee
information for each tax jurisdiction in which the U.S. MNE
does business. The financial information includes revenues,
profits, income taxes paid and accrued, stated capital,
accumulated earnings, and tangible assets other than cash.
Permanent establishment (PE). The term “permanent
establishment” includes:
A branch or business establishment of a constituent entity
•
in a tax jurisdiction that is treated as a permanent
establishment under an income tax convention to which that
tax jurisdiction is a party,
A branch or business establishment of a constituent entity
•
that is liable to tax in the tax jurisdiction in which it is located
pursuant to the domestic law of such tax jurisdiction, or
A branch or business establishment of a constituent entity
•
that is treated in the same manner for tax purposes as an
entity separate from its owner by the owner's tax jurisdiction
of residence.
Form 8975 and its Schedules A (Form 8975) must be filed
with the IRS with the income tax return of the ultimate parent
entity of a U.S. MNE group for the tax year in or within which
the reporting period covered by the Form 8975 ends.
Reporting period. The reporting period covered by Form
8975 and Schedules A (Form 8975) is generally the
12-month period of your applicable financial statement that
ends with or within your tax year. If you do not prepare an
annual applicable financial statement, then the reporting
period covered by Form 8975 and Schedules A (Form 8975)
is generally the 12-month period that ends on the last day of
your tax year.
Tax jurisdiction. A tax jurisdiction is a country or a
jurisdiction that is not a country but that has fiscal autonomy.
A U.S. territory or possession of the United States is
considered to have fiscal autonomy.
Tax jurisdiction of residence. A business entity is
generally considered a resident in a tax jurisdiction if, under
the laws of that tax jurisdiction, the business entity is liable for
tax therein based on place of management, place of
organization, or another similar basis. A business entity is not
considered a tax resident in a tax jurisdiction if the business
entity is liable for tax in such tax jurisdiction only by reason of
a tax imposed by reference to gross amounts of income
without any reduction for expenses, provided such tax
applies only with respect to income from sources in such tax
jurisdiction or capital situated therein.
Do not file Form 8975 and its Schedules A (Form
8975) separately from your income tax return.
!
CAUTION
Definitions
For more information on the terms below, see Regulations
section 1.6038-4.
Applicable financial statement. An applicable financial
statement is a certified audited financial statement that is
accompanied by a report of an independent certified public
accountant or similarly qualified independent professional
that is used for purposes of reporting to shareholders,
partners, or similar persons; for purposes of reporting to
creditors in connection with securing or maintaining
financing; or for any other substantial nontax purpose.
Business entity. A business entity is generally any entity
recognized for federal tax purposes that is not properly
classified as a trust under Regulations section 301.7701-4.
However, any grantor trust within the meaning of section 671,
all or a portion of which is owned by a person other than an
individual, is considered a business entity.
Sep 10, 2020
Cat. No. 69160R
A corporation that is organized or managed in a tax
jurisdiction that does not impose an income tax on
corporations will be treated as resident in that tax jurisdiction,
unless such corporation is treated as resident in another tax
jurisdiction under the previously described rules.
The tax jurisdiction of residence of a permanent
establishment is the jurisdiction in which the permanent
establishment is located.
traded on a public securities exchange in its tax jurisdiction of
residence).
Who Must File
A U.S. person must file Form 8975 and Schedules A (Form
8975) if it is the ultimate parent entity of a U.S. MNE group
with revenues of $850 million or more in the immediately
preceding reporting period. A U.S. territory ultimate parent
entity may designate a U.S. business entity to file on its
behalf.
A business entity that does not have a tax jurisdiction of
residence is considered “stateless.”
When making the determination of whether you are the
ultimate parent entity of a U.S. MNE group, a business
entity’s tax jurisdiction of residence is the business entity’s
country of organization if the business entity does not
otherwise have a tax jurisdiction of residence.
Exceptions from filing. You are not required to file Form
8975 if the annual revenue of your group for the immediately
preceding reporting period was less than $850 million.
Ultimate parent entity of a U.S. MNE group. The ultimate
parent entity of a U.S. MNE group is a U.S. business entity
that:
Owns directly or indirectly a sufficient interest in one or
•
more other business entities, at least one of which is
organized or tax resident in a tax jurisdiction other than the
United States, such that the U.S. business entity is required
to consolidate the accounts of the other business entities
with its own accounts under U.S. GAAP (or that would be so
required if publicly traded); and
When To File
Is not owned directly or indirectly by another business
•
Attach Form 8975 and Schedules A (Form 8975) to your
income tax return and file them with the IRS by the due date
(including extensions) for that income tax return. The Form
8975 and Schedules A (Form 8975) should be attached, as
applicable, to Forms 1120, 1120-C, 1120-RIC, 1065, 1120-S,
1120-L, 1120-PC, 1120-REIT, 990-T, and 1041.
entity that consolidates the accounts of such U.S. business
entity with its own accounts under GAAP in the other
business entity's tax jurisdiction of residence (or that would
be so required if publicly traded in its tax jurisdiction of
residence).
U.S. business entity. A U.S. business entity is a business
entity that is organized or has its tax jurisdiction of residence
in the United States. Foreign insurance companies that elect
to be treated as domestic corporations under section 953(d)
are U.S. business entities that have their tax jurisdiction of
residence in the United States. A business entity that is a
limited liability company that is organized in the United
States, and is wholly owned (directly) by another business
entity that has its tax jurisdiction of residence and is
organized in the United States, will be considered a U.S.
business entity that has its tax jurisdiction of residence in the
United States.
Extension of time to file. To request an extension of time
to file Form 8975, you must follow the instructions for the
income tax return to which Form 8975 and Schedules A
(Form 8975) will be attached.
How To File
Electronic Filing
If you file your income tax return electronically, see the
instructions for the income tax return for general information
about electronic filing.
If you are filing Forms 1120, 1065, 1120-S, 990-T, or 1041
electronically, you must attach Form 8975 and Schedules A
(Form 8975) electronically in the correct format, not as a
binary attachment.
U.S. MNE group. A U.S. MNE group comprises the ultimate
parent entity of a U.S. MNE group and all of the business
entities required to consolidate their accounts with the
ultimate parent entity's accounts under U.S. GAAP (or that
would be so required if publicly traded), regardless of
whether any such business entities could be excluded from
consolidation solely on size or materiality grounds.
Note. Beginning January 2021, Form 990-T can be filed
electronically.
Business entities are not considered part of the U.S. MNE
group if the income or assets of the business entities are
included in the financial statements of the ultimate parent
entity based on the equity method or fair value accounting.
U.S. territory or possession of the United States. The
term “U.S. territory or possession of the United States”
means American Samoa, Guam, the Northern Mariana
Islands, Puerto Rico, and the U.S. Virgin Islands.
U.S. territory ultimate parent entity. A U.S. territory
ultimate parent entity is a business entity organized in a U.S.
territory or possession of the United States that controls (as
defined in section 6038(e)) a U.S. business entity and that is
not owned directly or indirectly by another business entity
that consolidates the accounts of the U.S. territory ultimate
parent entity with its accounts under GAAP in the other
business entity's tax jurisdiction of residence (or would be so
required if equity interests in the other business entity were
Note. In order to ensure the timely automatic exchange of
the information on Form 8975 and Schedules A (Form 8975),
you are encouraged to file your return electronically. In
certain cases, you are required to file your return
electronically.
Amended Form 8975. If you file a Form 8975 and
Schedules A (Form 8975) that you later determine should be
amended, file an amended Form 8975 and all Schedules A
(Form 8975), including any that have not been amended,
with an amended tax return. Use the amended return
instructions for the return with which you originally filed Form
8975 and Schedules A (Form 8975) and check the amended
report checkbox at the top of Form 8975.
If the return and Form 8975 that you are amending were
filed electronically with the IRS, then the amended return and
Form 8975 should be filed electronically with the IRS in order
to ensure timely automatic exchange of the information on
Form 8975 and Schedules A (Form 8975).
-2-
Instructions for Form 8975 (Rev.12-2020)
Schedule A (Form 8975) that indicates the tax jurisdiction
“stateless.”
Where To File
While most entities will be electronically filing their country-by
country reports, some filers will not be able to file
electronically. This includes those filing Form 1120-REIT,
filers of Forms 1120-C, 1120-L, 1120-PC, and 1120-RIC that
are filing as parent entities, and filers of Form 1041 that
choose not to or are not required to file electronically. These
filers should use the mailing addresses provided for the
applicable income tax return. The Form 8975 and Schedules
A (Form 8975) must be attached to the applicable paper tax
return.
If a filer does not have either a U.S. Schedule A (Form 8975)
or a “stateless” Schedule A (Form 8975) that contains fiscally
transparent U.S. business entities, then the Form 8975 has
not been completed properly.
Part I—Identification of Filer
Use Part I to provide your identifying information.
Line 1a. Enter your complete legal name.
Line 1b. You are the reporting entity. Enter the code for your
reporting role. The reporting role indicates whether you are
filing as the ultimate parent entity of your group (enter code:
ULT) or if you are filing because you were designated by a
U.S. territory ultimate parent entity to file on its behalf (enter
code: SUR).
Paper-filed returns. If filing on paper only, mail a copy of
page 1 of your Form 8975 to the IRS. Mailing a copy of
page 1 of Form 8975 will notify the IRS that you have filed
Form 8975 and Schedules A (Form 8975) with a paper return
and will assist the IRS in identifying paper returns that have
Form 8975 and Schedules A (Form 8975) attached. Mail to
the following address:
Line 1c. Enter your employer identification number (EIN).
Lines 2 and 3a through 3c. Enter your legal address.
Include the suite, room, or other unit number after the street
address. If the post office does not deliver mail to the street
address and you have a P.O. box, show the box number
instead.
Internal Revenue Service
Mailstop 4950
1973 N. Rulon White Blvd.
Ogden, UT 84201
Foreign address. Follow the country's practice for
entering the postal code, if any. Do not abbreviate the
country name.
Record Maintenance
You are required to maintain records to support the
information provided on Form 8975 and Schedules A (Form
8975). However, you are not required to create and maintain
records that reconcile the amounts provided on Form 8975
and Schedules A (Form 8975) with the income tax returns of
any tax jurisdiction or your applicable financial statements.
Line 4. Enter the common name of the U.S. MNE group if it
is significantly different from the reporting entity's name on
line 1a.
Part II—Additional Information
You can enter additional information related to your group,
such as a narrative description of the overall business
operations and structure of your group or an overall
assumption or convention that you used which might have an
effect on your report. Any financial amounts entered in Part II
must be stated in U.S. dollars. You will have an opportunity to
enter specific information regarding financial information and
constituent entities in each tax jurisdiction on the appropriate
Schedule A (Form 8975).
Penalties for Failure To File
Penalties under section 6038(b) may apply for failure to
report the information required on this form.
Specific Instructions for Form
8975
There are two parts to Form 8975. You must complete the
information at the top of the form regarding reporting period
and Part I. Completing Part II is optional.
If the additional information you choose to enter in Part II
will not fit in the allotted space, complete as many additional
page 2, Part II, Additional Information sections as you need,
and submit these additional page(s) with Form 8975.
At the top of Form 8975, enter the reporting period for which
you are filing.
Note. If the common name of the U.S. MNE group is
significantly different from the reporting entity’s name, explain
in the Additional Information section.
earlier), check the amended report box.
Enter the number of Schedules A (Form 8975) attached to
Form 8975. You must attach at least one Schedule A (Form
8975) to your Form 8975 for each tax jurisdiction in which
your group operates, including the United States. Therefore,
you will file a separate Schedule A (Form 8975) for at least
two tax jurisdictions.
Specific Instructions for Schedule A
(Form 8975)
You must file a separate Schedule A (Form 8975) for each
tax jurisdiction in which your group has one or more
constituent entities resident. If you have any constituent
entities in your group that do not have a tax jurisdiction of
residence (that is, the constituent entity is “stateless”), then
you must also fill out a Schedule A (Form 8975) providing the
information for each constituent entity that is stateless,
reporting the financial and employee information in the
aggregate with respect to those stateless constituent entities,
and indicating that there is no tax jurisdiction by providing the
I—Tax Jurisdiction Information, later.
Generally, at least one Schedule A (Form 8975) will be for
the United States. However, certain U.S. MNE groups may
have only U.S.-organized constituent entities that are fiscally
transparent. These fiscally transparent U.S. business entities
do not have a tax jurisdiction of residence for purposes of
reporting information on Form 8975. Thus, these fiscally
transparent U.S. business entities, along with all other
constituent entities of the U.S. MNE group that do not have a
tax jurisdiction of residence, should be reported on one
-3-
Instructions for Form 8975 (Rev.12-2020)
The financial amounts furnished should be based on
applicable financial statements, books and records
maintained with respect to the constituent entities, regulatory
financial statements, or records used for tax reporting or
internal management control purposes for an annual period
of each constituent entity ending with or within the reporting
period.
be indicated in Part III, Additional Information, on the
Schedule A (Form 8975) relating to the amounts that are not
translated in accordance with U.S. GAAP.
Multiple Schedules A (Form 8975) for a Single
Tax Jurisdiction
If you are filing on paper and the information you want to
enter for a single tax jurisdiction does not fit on a single
Schedule A (Form 8975), you can attach additional
Schedules A (Form 8975). Complete the additional
Schedules A (Form 8975) as follows.
At the top of each Schedule A (Form 8975), enter the
reporting period, your name, and EIN. These should match
the information entered on Form 8975.
If a constituent entity in your group is the owner of another
constituent entity in your group that is stateless, then the
owner's share of such stateless entity's revenues and profits
should be aggregated with the information for the owner's tax
jurisdiction of residence.
Above Part I. Enter the reporting period beginning and
ending dates, the name of the reporting entity, and the EIN.
Part I. Enter the tax jurisdiction only. Do not complete lines
1 through 8 of Part I.
At each level, the owner entity includes its share of the
stateless entity’s revenue and profits in the owner’s tax
jurisdiction of residence only if the owner has a tax
jurisdiction of residence (that is, only if the owner is not
stateless), and the amount of revenue of the top-tier stateless
entity from which the owner entity calculates its share should
include any allocations from stateless entities owned, directly
or indirectly, by the top-tier stateless entity, even if such
allocations are excluded from the intermediate stateless
entity’s revenue and profit.
Part II. Complete Part II as needed to list all of the
constituent entities resident in the tax jurisdiction.
Part III. Enter a statement that indicates this is a
continuation sheet, the tax jurisdiction to which the
continuation sheet applies, and the page number of the
continuation sheets (for example, “Page 3 of 9”). Complete
the rest of Part III as necessary.
Part I—Tax Jurisdiction Information
For each tax jurisdiction in which one or more constituent
entities of your group is tax resident, you must provide
financial amounts and number of employees as an aggregate
of the information for the constituent entities resident in that
tax jurisdiction.
Example. Assume US Corp is the ultimate parent entity
of a U.S. MNE group. US Corp owns 90% of partnership P1,
which in turn owns 80% of partnership P2. Both P1 and P2
do not have a tax jurisdiction of residence (that is, they are
stateless), each earns $100 of revenue and has no expenses
(P1’s $100 of revenue does not include its allocable share of
P2’s revenue), and neither creates a permanent
Tax jurisdiction. This field is mandatory. Enter the
two-letter code for the tax jurisdiction to which the
Schedule A (Form 8975) pertains. The country code for the
United States is “US” and the country code for “stateless” is
“X5.” All other country codes can be found at IRS.gov/
Form 8975 and Schedule A (Form 8975) information is
exchanged using the OECD Country Code List that is based
on the ISO 3166-1 Standard. Although the country codes
found in the IRS link above contain the jurisdictions listed in
the table below, those jurisdictions do not correspond to a
valid OECD country code for purposes of exchanging the
information. Therefore, do not enter any of these country
codes on the tax jurisdiction line of Part I of Schedule A
(Form 8975).
establishment (that is, taxable presence) in any tax
jurisdiction. Assume US Corp earns $100 of revenue, not
including its share of P1’s revenue, and has no expenses.
P2 has $100 of revenue and profit that is reflected on the
stateless Schedule A (Form 8975) revenue and profit lines.
P1 has $100 of revenue and profit that is reflected on the
stateless Schedule A (Form 8975) revenue and profit lines.
Since P1 is stateless, it does not include its share of P2’s
revenue and profit again on the stateless Schedule A (Form
8975) revenue or profit lines. The total revenue and profit on
the stateless Schedule A (Form 8975) is $200.
US Corp has $100 of revenue and profit, not including any
allocations from other constituent entities. Since US Corp
has a tax jurisdiction of residence, it includes its share of P1’s
revenue and profit on the Schedule A (Form 8975) for the
United States. P1’s revenue and profit, of which US Corp is
allocated 90%, includes any allocations from stateless
entities that P1 owns, even if such allocations were not
included on the stateless Schedule A (Form 8975) revenue
or profit lines. P1’s revenue and profit when determining US
Corp’s allocable share is $180 (P1’s own $100 of revenue
and profit plus 80% of P2’s revenue and profit, or $80). US
Corp is allocated 90% of $180, or $162, of revenue and profit
due to its ownership of P1. The total revenue and profit on
the United States Schedule A (Form 8975) revenue and profit
lines is US Corp’s own revenue and profit of $100 plus its
allocation of $162 of revenue and profit from P1, or $262.
Tax Jurisdiction
Country Code
Akrotiri
AX
AT
IP
Ashmore and Cartier Islands
Clipperton Island
Coral Sea Islands
Dhekelia
CR
DX
PF
PG
Paracel Islands
Spratly Islands
If the tax jurisdiction specified in the above list is
associated with a larger sovereignty, use the country code for
the larger sovereignty with which the tax jurisdiction is
associated (for example, Akrotiri and Dhekelia are
Currency Translation
All currency amounts furnished must be in U.S. dollars. If an
exchange rate is used other than in accordance with U.S.
GAAP for translation to U.S. dollars, the exchange rate must
considered a British Overseas Territory so the country code
for the United Kingdom would be used (“UK”)). Otherwise,
-4-
Instructions for Form 8975 (Rev.12-2020)
use a separate Schedule A (Form 8975) for “other country”
using the tax jurisdiction code “OC.” In either case, you
should include in Part III of Schedule A (Form 8975) the
name of the specific constituent entity and the jurisdiction
where the constituent entity is located.
all other tax jurisdictions. Taxes paid should include
withholding taxes paid by other entities (whether related or
unrelated) with respect to payments to the constituent
entities in Part II.
Example. If, during a reporting period, Company X
(resident in tax jurisdiction X) generates operating income in
tax jurisdiction X that is subject to corporate income tax in tax
jurisdiction X and earns interest income from a company in
tax jurisdiction Y subject to withholding tax in tax jurisdiction
Y, the taxes paid to tax jurisdiction X on the operating income
and the tax withheld on the interest and paid to tax
jurisdiction Y should be reported as part of the income taxes
paid by Company X on the Schedule A (Form 8975) for tax
jurisdiction X.
When you enter a country code in Schedule A (Form
8975), Part I, the financial and employee information
!
CAUTION
in Part I, the constituent entity information in Part II,
and the additional information in Part III, must pertain to the
constituent entities that are tax resident in that jurisdiction.
In Part I, you will provide the aggregate amounts for all of
the constituent entities listed in Part II.
Lines 1a through 1c. On line 1a, enter the aggregate
revenues of the constituent entities listed in Part II that are
generated from transactions with those that are not
constituent entities in your group. On line 1b, enter the
aggregate revenues of the constituent entities listed in Part II
that are generated from transactions with other constituent
entities in your group. On line 1c, enter the total aggregate
revenues of the constituent entities listed in Part II.
The term “revenue” includes all amounts of revenue,
including revenue from sales of inventory and property,
services, royalties, interest, and premiums.
Revenue does not include payments received from other
constituent entities in your group that are treated as
dividends in the payor's tax jurisdiction of residence.
Distributions and remittances from your constituent entities
that are partnerships, other fiscally transparent entities, or
permanent establishments are not considered revenue of the
recipient-owner.
Revenue also does not include imputed earnings or
deemed dividends from other constituent entities in your
group that are taken into account solely for tax purposes and
that otherwise would be included as revenue by a constituent
entity.
For a constituent entity that is an exempt organization,
revenue means only revenue that is reflected in unrelated
business taxable income. See Regulations section
1.6038-4(d)(3)(ii).
Line 4. Enter the aggregate of the total accrued current
income tax expense recorded on taxable profits or losses,
reflecting only operations in the relevant annual period and
excluding deferred taxes or provisions for uncertain tax
liabilities, for the constituent entities listed in Part II.
When a constituent entity listed in Part II is a permanent
establishment, the amounts on line 3 and line 4 should not
include the income tax paid or current income tax expense
accrued by the business entity of which the permanent
establishment would otherwise be a part in that business
entity’s tax jurisdiction of residence on the income derived by
the permanent establishment. For example, if Company X
(resident in tax jurisdiction X) has a permanent establishment
“PE Y” in tax jurisdiction Y that is considered a constituent
entity, and Company X pays tax jurisdiction X income tax on
income earned by PE Y, then that income tax paid should be
reflected on the Schedule A (Form 8975) for tax jurisdiction
X. However, income tax paid to tax jurisdiction Y on income
earned by PE Y is not included on the Schedule A (Form
8975) for tax jurisdiction X, but rather on the Schedule A
(Form 8975) for tax jurisdiction Y.
Line 5. Enter the aggregate amount of the stated capital of
the constituent entities listed in Part II.
The stated capital of a permanent establishment must be
reported in the tax jurisdiction of residence of the legal entity
of which it is a permanent establishment unless there is a
defined capital requirement in the permanent establishment
tax jurisdiction for regulatory purposes.
Line 2. Enter the aggregate profit or loss before income tax
of the constituent entities listed in Part II.
Line 6. Enter the aggregate of total accumulated earnings of
the constituent entities listed in Part II. However, the
Consistent with the definition of revenue, profit or loss
before income tax does not include payments received from
other constituent entities in your group that are treated as
dividends in the payor's tax jurisdiction.
accumulated earnings of a permanent establishment are
considered those of the legal entity of which it is a permanent
establishment and should be reported on the Schedule A
(Form 8975) for the tax jurisdiction of the legal entity owner.
Note. An amount representing all or part of a constituent
entity's profit that is required or permitted for financial
reporting purposes to be included in the profit before tax of
another constituent entity in the group should be treated in
the same way as dividends from other constituent entities
and excluded from revenue and profit or loss before income
tax. This instruction does not apply where a constituent entity
includes in profit before tax for financial reporting purposes
an amount representing all or part of the profit of another
constituent entity in the group that is fiscally transparent.
Line 3. Enter the aggregate amount of income tax paid on a
cash basis to all tax jurisdictions by the constituent entities
listed in Part II and any taxes withheld on payments received
by the constituent entities listed in Part II.
Line 7. Enter the aggregate number of employees on a
full-time equivalent basis of the constituent entities listed in
Part II. The number of employees may be reported as of the
year-end, on the basis of average employment levels for the
year, or on any other basis consistently applied across tax
jurisdictions of your group and from year to year.
Reasonable rounding or approximation of the number of
employees is permissible, provided that such rounding or
approximation does not materially distort the relative
distribution of employees across the various tax jurisdictions
of your group. Consistent approaches should be applied from
year to year and across entities.
Line 8. Enter the aggregate of the net book value of tangible
Taxes paid should include taxes paid in cash by a
assets of all the constituent entities listed in Part II. For
constituent entity listed in Part II to its tax jurisdiction and to
-5-
Instructions for Form 8975 (Rev.12-2020)
purposes of this schedule, tangible assets do not include
cash or cash equivalents, intangibles, or financial assets.
For permanent establishments, assets should be reported
on the Schedule A (Form 8975) for the tax jurisdiction in
which the permanent establishment is located.
CBC502 Holding or managing intellectual property
CBC503 Purchasing or procurement
CBC504 Manufacturing or production
CBC505 Sales, marketing, or distribution
CBC506 Administrative, management, or support services
CBC507 Provision of services to unrelated parties
CBC508 Internal group finance
•
•
•
•
•
•
•
•
•
•
•
•
Part II—Constituent Entity
Information
CBC509 Regulated financial services
CBC510 Insurance
In this section, you will provide constituent entity information
for your group regarding the constituent entities that have the
tax jurisdiction indicated in Part I. You should complete a row
for each constituent entity providing the information indicated
below.
CBC511 Holding shares or other equity instruments
CBC512 Dormant
CBC513 Other
Those that do not file electronically are limited to indicating
a maximum of three main business activities. However, if you
feel this does not properly reflect the main businesses of a
constituent entity, you may use Part III, Additional
Information, on the appropriate Schedule A (Form 8975) to
enter additional codes and explain.
Line 1. Enter the full legal name of the constituent entity,
including the domestic designation for the legal form, as
indicated in its articles of incorporation or any similar
document. If the constituent entity is a permanent
establishment, the naming convention to use is the name of
the constituent entity of which the permanent establishment
would be a part (if it were not its own constituent entity),
followed by “- (PE).” For instance, if XYZ Corp has a
permanent establishment, that permanent establishment’s
name would be “XYZ Corp - (PE).”
Line 5b. If you entered the code for “Other” on line 4a,
describe the “Other” business activity.
Part III—Additional Information
Briefly describe the sources of data used in preparing Parts I
and II of the Schedule A (Form 8975). The description should
be sufficient to enable an understanding of the source of
each item of information supplied on the Schedule A (Form
8975). The source(s) of data could include consolidation
reporting packages, separate entity financial statements,
regulatory financial statements, tax reporting records, or
internal management accounts reports. If a change is made
to the source of data used from year to year, explain the
reasons for the change and its consequences.
If filing electronically, the address of the constituent entity
may also be provided.
Line 2. Enter the entity role used by the constituent entity as
one of the following values.
CBC801 Ultimate Parent Entity
•
•
•
CBC802 Reporting Entity
CBC803 Both (Ultimate Parent Entity and Reporting Entity)
If the roles above do not apply to the constituent entity role,
leave blank.
Additionally, you can enter any relevant information or
explanation that you deem necessary or that would facilitate
the understanding of the information provided in Parts I and
II. The information may or may not relate to a specific
constituent entity. The information may be used to explain
the tax jurisdiction financial and employee information in Part
I. You can use the item reference codes listed next to
indicate if the additional information relates to a specific item
in Part I.
Line 3. Enter the tax identification number (TIN), if any, used
for the constituent entity by the tax administration in the tax
jurisdiction of residence. The TIN is a mandatory field and
must be entered for each constituent entity. If the constituent
entity does not have a TIN, then enter “NOTIN.”
If filing electronically, one or more entity identification
numbers (IN), such as a company registration number, can
be provided, along with the IN’s issuer country and type.
CountryCodes, enter the tax jurisdiction in which the
constituent entity is organized or incorporated if different from
the tax jurisdiction of residence. However, see Tax
for codes that are not allowed.
CBC601 Revenues—unrelated party
CBC602 Revenues—related party
CBC603 Revenues—total
CBC604 Profit or loss
•
•
•
•
•
•
•
•
•
•
CBC605 Income tax paid
CBC606 Income tax accrued
CBC607 Stated capital
CBC608 Accumulated earnings
CBC609 Number of employees
CBC610 Tangible assets
Line 5a. Identify the nature of the main business activity of
the constituent entity in the relevant tax jurisdiction by
selecting at least one of the following codes or categories.
CBC501 Research and development
•
Paperwork Reduction Act Notice. We ask for the information on this form to carry out the Internal Revenue laws of the
United States. You are required to give us the information. We need it to ensure that you are complying with these laws and to
allow us to figure and collect the right amount of tax.
You are not required to provide the information requested on a form that is subject to the Paperwork Reduction Act unless
the form displays a valid OMB control number. Books or records relating to a form or its instructions must be retained as long
as their contents may become material in the administration of any Internal Revenue law. Generally, tax returns and return
information are confidential, as required by section 6103.
The time needed to complete and file this form and related schedules will vary depending on individual circumstances. The
estimated burden for taxpayers filing this form is approved under OMB control number 1545-2272. The estimated burden for all
other taxpayers who file this form is shown below.
-6-
Instructions for Form 8975 (Rev.12-2020)
Form 8975 and Schedule A (Form 8975)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1hr., 30 min.
If you have comments concerning the accuracy of these time estimates or suggestions for making this form and related
schedule simpler, we would be happy to hear from you. See the instructions for the tax return with which this form is filed.
-7-
Instructions for Form 8975 (Rev.12-2020)