On 29 June 2016, the U.S. Treasury Department released the final regulations (TD 9773) for the implementation of Country-by-Country (CbC) reporting. Overall, the final regulations generally mirror the proposed regulations released in December 2015 ({News-2015-12-23/P/2- previous coverage}), although certain amendments have been made for clarification. General Requirements to File CbC Report The CbC reporting requirements as included in the final regulations apply for U.S. resident ultimate parent entities of MNE groups, and stipulate that such MNEs are required to file a CbC report if annual group revenue meets or exceeds USD 850 million in the preceding reporting period. The final...