US IRS provides instructions for amending country-by-country reports on multinationals

The US IRS today updated its frequently asked questions on country-by-country reporting to address how a US multinational enterprise (MNE) should proceed if it needs to to modify or correct a submitted Form 8975 and Schedule A.

The Service said the MNE must file an amended Form 8975 and all Schedules A (Form 8975), including any that have not been amended, with its amended tax return and file using the same method (electronically or by paper) as the original submission. Providing only the amended information is not sufficient, the IRS said.

The IRS also today reminded US MNEs filing Form 8975 on paper to follow the instructions carefully so that the data can be converted for electronic exchange with other tax authorities.

In particular, the Service notes that filers must:

  • File a separate Schedule A (Form 8975) for each tax jurisdiction where the MNE group operates and list all of the constituent entities resident in the tax jurisdiction. Note: At least one constituent entity must be listed on each Schedule A.
  • Attach at least two Schedules A (Form 8975) to the Form 8975. In most cases, at least one Schedule A should be for the United States.
  • Enter the tax identification number (TIN), if any, used for each constituent entity. If the constituent entity does not have a TIN, then enter “NOTIN”. Do not leave the TIN field blank.

Also, if an MNE is filing on paper, it should mail a copy of only page 1 of Form 8975 to Ogden to notify the IRS that it has filed Form 8975 and Schedules A (Form 8975) with a paper return, the Service said.

The Service said that Instructions for Form 8975 and Schedule A (Form 8975) can be referenced for further guidance.

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