Instructions For Form 8975 And Schedule A (Form 8975) - Country-By-Country Report (Page 4 of 6) in pdf

should be aggregated with the information for the owner's tax

Part I. Enter the tax jurisdiction only. Do not complete lines

jurisdiction of residence.

1 through 8 of Part I.

At each level, the owner entity includes its share of the

Part II. Complete Part II as needed to list all of the

stateless entity’s revenue and profits in the owner’s tax

constituent entities resident in the tax jurisdiction.

jurisdiction of residence only if the owner has a tax

Part III. Enter a statement that indicates this is a

jurisdiction of residence (that is, only if the owner is not

continuation sheet, the tax jurisdiction to which the

stateless), and the amount of revenue of the top-tier stateless

continuation sheet applies, and the page number of the

entity from which the owner entity calculates its share should

continuation sheets (for example, “Page 3 of 9”). Complete

include any allocations from stateless entities owned, directly

the rest of Part III as necessary.

or indirectly, by the top-tier stateless entity, even if such

Part I—Tax Jurisdiction Information

allocations are excluded from the intermediate stateless

entity’s revenue and profit.

For each tax jurisdiction in which one or more constituent

Example. Assume US Corp is the ultimate parent entity

entities of your group is tax resident, you must provide

of a U.S. MNE group. US Corp owns 90% of partnership P1

financial amounts and number of employees as an aggregate

which in turn owns 80% of partnership P2. Both P1 and P2

of the information for the constituent entities resident in that

do not have a tax jurisdiction of residence (that is, they are

tax jurisdiction.

stateless), each earns $100 of revenue and has no expenses

Tax jurisdiction. This field is mandatory. Enter the

(P1’s $100 of revenue does not include its allocable share of

two-letter code from the list at

IRS.gov/CountryCodes

for the

P2’s revenue), and neither creates a permanent

tax jurisdiction to which the Schedule A (Form 8975)

establishment (that is, taxable presence) in any tax

pertains. If the Schedule A (Form 8975) is for “stateless”

jurisdiction. Assume US Corp earns $100 of revenue, not

information, enter “X5.”

including its share of P1’s revenue, and has no expenses.

P2 has $100 of revenue and profit that is reflected on the

When you enter a country code in Schedule A (Form

stateless Schedule A revenue and profit lines. P1 has $100

8975), Part I, the financial and employee information

of revenue and profit that is reflected on the stateless

in Part I, the constituent entity information in Part II,

CAUTION

Schedule A revenue and profit lines. Since P1 is stateless, it

and the additional information in Part III must pertain to the

does not include its share of P2’s revenue and profit again on

constituent entities that are tax resident in that jurisdiction.

the stateless Schedule A revenue or profit lines. The total

In Part I, you will provide the aggregate amounts for all of

revenue and profit on the stateless Schedule A is $200.

the constituent entities listed in Part II.

US Corp has $100 of revenue and profit, not including any

Lines 1a through 1c. In line 1a, enter the aggregate

allocations from other constituent entities. Since US Corp

revenues of the constituent entities listed in Part II that are

has a tax jurisdiction of residence, it includes its share of P1’s

generated from transactions with those that are not

revenue and profit on the Schedule A for the United States.

constituent entities in your group. In line 1b, enter the

P1’s revenue and profit, of which US Corp is allocated 90%,

aggregate revenues of the constituent entities listed in Part II

includes any allocations from stateless entities that P1 owns,

that are generated from transactions with other constituent

even if such allocations were not included on the stateless

entities in your group. In line 1c, enter the total aggregate

Schedule A revenue or profit lines. P1’s revenue and profit

revenues of the constituent entities listed in Part II.

when determining US Corp’s allocable share is $180 (P1’s

own $100 of revenue and profit plus 80% of P2’s revenue

The term “revenue” includes all amounts of revenue,

and profit, or $80). US Corp is allocated 90% of $180, or

including revenue from sales of inventory and property,

$162, of revenue and profit due to its ownership of P1. The

services, royalties, interest, and premiums.

total revenue and profit on the United States Schedule A

Revenue does not include payments received from other

revenue and profit lines is US Corp’s own revenue and profit

constituent entities in your group that are treated as

of $100 plus its allocation of $162 of revenue and profit from

dividends in the payor's tax jurisdiction of residence.

P1, or $262.

Distributions and remittances from your constituent entities

that are partnerships, other fiscally transparent entities, or

Currency Translation

permanent establishments are not considered revenue of the

All currency amounts furnished must be in U.S. dollars. If an

recipient-owner.

exchange rate is used other than in accordance with U.S.

Revenue also does not include imputed earnings or

GAAP for translation to U.S. dollars, the exchange rate must

deemed dividends from other constituent entities in your

be indicated in Part III, Additional Information, on the

group that are taken into account solely for tax purposes and

Schedule A (Form 8975) relating to the amounts that are not

that otherwise would be included as revenue by a constituent

translated in accordance with U.S. GAAP.

entity.

Multiple Schedules A (Form 8975) for a Single

For a constituent entity that is an exempt organization,

revenue means only revenue that is reflected in unrelated

Tax Jurisdiction

business taxable income. See Regulations section

If you are filing on paper and the information you want to

1.6038-4(d)(3)(ii).

enter for a single tax jurisdiction does not fit on a single

Schedule A (Form 8975), you can attach additional

Line 2. Enter the aggregate profit or loss before income tax

Schedules A (Form 8975). Complete the additional

of the constituent entities listed in Part II.

Schedules A (Form 8975) as follows.

Line 3. Enter the aggregate amount of income tax paid on a

cash basis to all tax jurisdictions by the constituent entities

Above Part I. Enter the reporting period beginning and

listed in Part II and any taxes withheld on payments received

ending dates, the name of the reporting entity, and the EIN.

by the constituent entities listed in Part II.

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Instructions for Form 8975 (June 2017)

Instructions For Form 8975 And Schedule A (Form 8975) - Country-By-Country Report Page 4

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