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The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
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
jurisdiction of residence (that is, only if the owner is not Part III. Enter a statement that indicates this is a
stateless), and the amount of revenue of the top-tier stateless continuation sheet, the tax jurisdiction to which the
entity from which the owner entity calculates its share should continuation sheet applies, and the page number of the
include any allocations from stateless entities owned, directly continuation sheets (for example, “Page 3 of 9”). Complete
or indirectly, by the top-tier stateless entity, even if such the rest of Part III as necessary.
allocations are excluded from the intermediate stateless
Part I—Tax Jurisdiction Information
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
(P1’s $100 of revenue does not include its allocable share of Tax jurisdiction. This field is mandatory. Enter the
P2’s revenue), and neither creates a permanent two-letter code for the tax jurisdiction to which the
establishment (that is, taxable presence) in any tax Schedule A (Form 8975) pertains. The country code for the
jurisdiction. Assume US Corp earns $100 of revenue, not United States is “US” and the country code for “stateless” is
including its share of P1’s revenue, and has no expenses. “X5.” All other country codes can be found at IRS.gov/
CountryCodes.
P2 has $100 of revenue and profit that is reflected on the
stateless Schedule A revenue and profit lines. P1 has $100 Form 8975 and Schedule A (Form 8975) information is
of revenue and profit that is reflected on the stateless exchanged using the OECD Country Code List that is based
Schedule A revenue and profit lines. Since P1 is stateless, it on the ISO 3166-1 Standard. Although the country codes
does not include its share of P2’s revenue and profit again on found in the IRS link above contain the jurisdictions listed in
the stateless Schedule A revenue or profit lines. The total the table below, those jurisdictions do not correspond to a
revenue and profit on the stateless Schedule A is $200. valid OECD country code for purposes of exchanging the
information. Therefore, do not enter any of these country
US Corp has $100 of revenue and profit, not including any
codes on the tax jurisdiction line of Part I of Schedule A
allocations from other constituent entities. Since US Corp
(Form 8975).
has a tax jurisdiction of residence, it includes its share of P1’s
revenue and profit on the Schedule A for the United States. Tax Jurisdiction Country Code
P1’s revenue and profit, of which US Corp is allocated 90%,
includes any allocations from stateless entities that P1 owns, Akrotiri AX
even if such allocations were not included on the stateless Ashmore and Cartier Islands AT
Schedule A revenue or profit lines. P1’s revenue and profit Clipperton Island IP
when determining US Corp’s allocable share is $180 (P1’s
own $100 of revenue and profit plus 80% of P2’s revenue Coral Sea Islands CR
and profit, or $80). US Corp is allocated 90% of $180, or Dhekelia DX
$162, of revenue and profit due to its ownership of P1. The
Paracel Islands PF
total revenue and profit on the United States Schedule A
revenue and profit lines is US Corp’s own revenue and profit Spratly Islands PG
of $100 plus its allocation of $162 of revenue and profit from
P1, or $262.
If the tax jurisdiction specified in the above list is
Currency Translation associated with a larger sovereignty, use the country code for
All currency amounts furnished must be in U.S. dollars. If an the larger sovereignty with which the tax jurisdiction is
exchange rate is used other than in accordance with U.S. associated (e.g., Akrotiri and Dhekelia are considered a
GAAP for translation to U.S. dollars, the exchange rate must British Overseas Territory so the country code for the United
be indicated in Part III, Additional Information, on the Kingdom would be used (“UK”)). Otherwise, use a separate
Schedule A (Form 8975) relating to the amounts that are not Schedule A for “other country” using the tax jurisdiction code
translated in accordance with U.S. GAAP. “OC.” In either case, you should include in Part III of
Schedule A (Form 8975) the name of the specific constituent
Multiple Schedules A (Form 8975) for a Single entity and the jurisdiction where the constituent entity is
Tax Jurisdiction located.
If you are filing on paper and the information you want to When you enter a country code in Schedule A (Form
enter for a single tax jurisdiction does not fit on a single ! 8975), Part I, the financial and employee information
Schedule A (Form 8975), you can attach additional CAUTION in Part I, the constituent entity information in Part II,
Schedules A (Form 8975). Complete the additional and the additional information in Part III must pertain to the
Schedules A (Form 8975) as follows. constituent entities that are tax resident in that jurisdiction.
Above Part I. Enter the reporting period beginning and In Part I, you will provide the aggregate amounts for all of
ending dates, the name of the reporting entity, and the EIN. the constituent entities listed in Part II.
-4- Instructions for Form 8975 (Rev. July 2019)
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