We have published our comment letter on HM Treasury draft Regulations and draft guidance on CRD IV country-by-country reporting (CBCR).  In our view there are a number of areas which still require additional consideration.

These are: 

• The definition of “consolidation” and how it is interpreted in practice.  We comment that we have identified “many scenarios where the results of entities outside the scope of CRD IV will be disclosed which appear contrary to the government’s stated intentions at Paragraph 3.10 of the Summary of Responses document” (link to HM Treasury website).  This states that “it is not the government’s intention to capture institutions that are not in the scope of CRD4”.  We would like institutions “to be permitted to exclude non-institution subsidiaries from their CBCR disclosure if they prefer”.  
• The inclusion of additional requirements into the statutory audit report.  We comment that “it is inappropriate to establish a precedent for information not directly relevant to the shareholders being included within the audit report”. 
• The fixed deadline for reporting.  We comment that this deadline will be difficult for some to comply with.  We propose that the deadline “be set as the number of months after each institution’s year end”. 

There are also a number of areas where we feel that additional clarification and/or guidance is required.  These areas include; the definition of ‘corporation tax paid’ and the concept of materiality within CBCR. 

Our full comment letter can be obtained below.

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