On 5 October 2015, the UK HMRC launched a public consultation on the Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2015, which implements the country-by-country (CbC) reporting requirement developed as part of Action 13 of the OECD BEPS Project. The UK will also require the master file and local file included in the Action 13 guidelines, but no new legislat…