FBR| Federal Board of Revenue - Government of Pakistan

27Q. Documents, reports, information and details required to be furnished under Part II of this Chapter by electronic transmission using the specified software in accordance with the specified format or any other requirements including safety valve, security and verification considerations as may be specified by the Federal Board of Revenue from time to time:

Provided that till the time such specified software in accordance with the specified format or any other requirements is developed or procured and installed, the documents, reports, information and details shall be furnished electronically via electronic mail on electronic mail address, namely, cbcr@fbr.gov.pk.”;

Schedule

[see rule 27G(2)]

Country-by-Country Report

1. Is this an amended report? Yes ____ No ____

2. Enter the last day of reporting tax year of the MNE group for which you are reporting (see instruction) Year Month Day

3. Does this report cover a full reporting tax year ? Yes ____ No ___

4. If no, indicate the number of month for which you are reporting_____________________

Reporting Entity Section

Section 1

Reporting Entity Identification

Form A

Check one box only to indicate the type of reporting entity and complete the areas that apply
Person (Company/Trust/AOP) Incorporation/Registration Number
Enter the name of MNE group
Reporting Entity’s address
Street Number	Street
City	Province or territory	Country code	Postal code

Section 2

Role of the Reporting Entity

Check one box only to indicate the reporting role of the entity filing this report (see instructions)

Ultimate parent entity

Surrogate parent entity

Constituent entity

If you selected constituent entity, is this report filed on behalf of all constituent entities of the MNE group in Pakistan for the reporting fiscal year?

_____Yes _____No

If you selected surrogate parent entity or constituent entity, provide the name and country of residence for tax purposes of the ultimate parent entity.

_______________________________________________________________________________________________ _________Name of ultimate parent entity Country code

Section 3

Certification

I certify that the information given on this form is, to my knowledge, correct and complete, and fully discloses the reporting entity’s related information		If someone other than the reporting entity prepared this form, provide their;
Name of certifier		Name of contact
Sign here (it is a serious offence to file a false statement)		Address
Position/title of certifier
Telephone number of certifier	Date (DD-MM-YYYY)	Telephone number of contact

COUNTRY-BY-COUNTRY Report

TABLE 1

Overview of allocation of income, taxes and business activities by tax jurisdiction

Name of the MNE group: Fiscal year concerned: Currency:
Tax Jurisdiction	Revenues			Profit (Loss) Before Income Tax	Income Tax Paid (on cash basis	Income Tax Accrued – Current Year	Stated capital	Accumulated earnings	Number of Employees	Tangible Assets other than Cash and Cash Equivalents
Tax Jurisdiction	Unrelated Party	Related Party	Total	Profit (Loss) Before Income Tax	Income Tax Paid (on cash basis	Income Tax Accrued – Current Year	Stated capital	Accumulated earnings	Number of Employees	Tangible Assets other than Cash and Cash Equivalents
(1)	(2)	(3)	(4)	(5)	(6)	(7)	(8)	(9)	(10)	(11)

TABLE 2

List of all the Constituent Entities of the MNE group included in each aggregation per tax jurisdiction

Name of the MNE group: Fiscal year concerned:
Tax Jurisdiction	Constituent Entities resident in the Tax Jurisdiction	Tax Jurisdiction of organisation or incorporation if different from Tax Jurisdiction of Residence	Main business activity(ies)
Tax Jurisdiction	Constituent Entities resident in the Tax Jurisdiction		Research and Development	Holding/managing intellectual property	Purchasing or Procurement	Manufacturing or Production	Sales, Marketing or Distribution	Administrative, Management or Support Services	Provision of services to unrelated parties	Internal Group Finance	Regulated Financial Services	Insurance	Holding shares or other equity instruments	Dormant	Other ^{^[1]}
(1)	(2)	(3)	(4)	(5)	(6)	(7)	(8)	(9)	(10)	(11)	(12)	(13)	(14)	(15)	(16)
	1.
	2.
	3.
	1.
	2.
	3.

TABLE 3

Additional Information

Name of the MNE group: Fiscal year concerned:
Please include any further brief information or explanation you consider necessary or that would facilitate the understanding of the compulsory information provided in the country-by-country report.

	”.

Rule 27 Q