Välj språk
  1. Hem
  2. Dokumentation
  3. Instruktioner
  4. USA
  5. Skatter
  6. Form 8975 Instruktioner inklusive schema A

Form 8975 Instruktioner inklusive schema A

Instruktioner för formulär 8975 och schema A (Form 8975), land-för-länder rapport

Rev. december 2020

Relaterade formulär

Detaljer
Filformat PDF
Storlek 153.2 KB
Ladda ner
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  
filers described under Who Must File to annually report  
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.  
If filing an amended report (see Amended Form 8975,  
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  
appropriate “stateless” code. See Tax jurisdiction under Part  
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.  
Line 4. Using the two-letter code from the list at IRS.gov/  
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  
jurisdiction under Part I—Tax Jurisdiction Information, earlier,  
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)